What are the facts?
Washington State enacted a statute establishing a Minimum Wage and Industrial Welfare Commission empowered to set minimum wages for women and minors to protect their health and morals. Elsie Parrish worked as a chambermaid for West Coast Hotel Company in Washington and was paid less than the minimum wage fixed by the state's administrative body. Parrish sued to recover the difference between the wages she received and the statutory minimum. The hotel defended on the ground that the minimum wage law violated the Fourteenth Amendment's Due Process Clause by infringing the liberty of contract recognized in prior cases like Adkins v. Children's Hospital. The Supreme Court of Washington upheld the statute and ruled in Parrish's favor. The employer sought review in the United States Supreme Court, presenting the question whether Washington's minimum wage law for women was unconstitutional under the Due Process Clause.
What is the legal issue?
Does a state statute that sets a minimum wage for women violate the liberty of contract protected by the Due Process Clause of the Fourteenth Amendment?
What rule applies?
The liberty safeguarded by the Due Process Clause is not an absolute freedom of contract; it is subject to the state's police power to protect the health, safety, morals, and general welfare. Economic regulations, including minimum wage laws, are constitutional if they are reasonable, nonarbitrary measures that bear a real and substantial relation to a legitimate public purpose. To the extent Adkins v. Children's Hospital held otherwise, it is overruled.
What did the court hold?
No. Washington's minimum wage law for women is a reasonable exercise of the state's police power and does not violate the Due Process Clause. The judgment of the Supreme Court of Washington is affirmed, and Adkins v. Children's Hospital is overruled.
What is the reasoning?
Chief Justice Hughes, writing for the Court, emphasized that the Constitution does not enshrine an absolute freedom of contract. Property and contract rights have long been subject to reasonable restraints for the common good. Drawing on Nebbia v. New York, the Court explained that the proper inquiry is whether the regulation is reasonably related to a legitimate legislative end and is not arbitrary or capricious. The legislature could rationally conclude that women as a class often face unequal bargaining power and are vulnerable to exploitation, and that substandard wages undermine health and welfare and shift costs to the broader community through poverty and charitable relief. The Court rejected the distinction drawn in Adkins between maximum hours and minimum wage laws, explaining that there is no constitutional difference in principle: both are instruments to prevent the evils accompanying exploitative labor conditions. A minimum wage bears a real and substantial relation to the permissible objective of protecting health and welfare. The statute at issue was confined to women, the class the legislature determined most in need of protection, and the Court deferred to the legislature's judgment about the existence of the underlying economic and social facts. Because the law was neither arbitrary nor discriminatory in a constitutionally impermissible way, it satisfied due process. In explicitly overruling Adkins, the Court repudiated the Lochner-era conception of substantive due process that invalidated economic regulations on the ground that they interfered with a supposed constitutional right to contract on any terms.
Why is this case significant?
West Coast Hotel marks the decisive end of the Lochner era and inaugurates modern deference to economic regulation under the Due Process Clause. It established the rational basis framework for reviewing state regulation of wages, prices, and labor conditions, clearing constitutional space for New Deal and later social-welfare legislation. The decision directly overruled Adkins, effectively displacing earlier cases that had constitutionalized a strong liberty of contract. For law students, the case is pivotal in understanding the evolution of substantive due process, the Court's changing posture toward legislative fact-finding and social policy, and the separation of powers implications of judicial deference in the economic realm. It also frames later developments, including United States v. Carolene Products (Footnote Four) and United States v. Darby, which cemented federal and state authority to regulate economic life.
Did West Coast Hotel overrule Lochner v. New York?
Not explicitly. The Court expressly overruled Adkins v. Children's Hospital, the case striking down a minimum wage for women. However, West Coast Hotel repudiated the broader Lochner-era approach that treated liberty of contract as a near-absolute limit on economic regulation. In practice, it ended the Lochner era and replaced it with a deferential reasonableness (rational basis) review of economic legislation.
What standard of review did the Court apply to the minimum wage law?
A deferential reasonableness test, often described as rational basis review. The Court asked whether the law was a reasonable, nonarbitrary means to achieve a legitimate public purpose—here, protecting health and welfare and preventing exploitation due to unequal bargaining power. Finding a real and substantial relation between the minimum wage and those ends, the Court upheld the statute.
How does West Coast Hotel relate to Nebbia v. New York?
Nebbia upheld state price controls on milk, reasoning that due process is satisfied if regulation is reasonable and serves a legitimate public end. West Coast Hotel extended that reasoning to wage regulation, confirming that the same deferential standard governs legislative choices in economic policy, including minimum wage laws.
Was the decision limited to women-only minimum wage laws?
The statute at issue applied to women and minors, and the Court analyzed it on that basis. Nonetheless, the Court's reasoning—emphasizing the state's authority to address unequal bargaining power and protect health and welfare—was not inherently gender-specific. Soon after, broad minimum wage and labor standards for all workers were enacted at the federal level and sustained in United States v. Darby (1941).
What role did Justice Roberts's vote play in the outcome?
Justice Roberts joined the Hughes majority, producing a 5–4 decision and departing from his vote the year before in Tipaldo, which had followed Adkins to strike down a minimum wage law. Popularly dubbed the "switch in time that saved nine," his vote has been linked—controversially—to political pressure from President Roosevelt's court-reform plan. Historians debate causation, noting that Roberts had already sided with a deferential approach in Nebbia and that conference votes in West Coast Hotel predated the plan's announcement.
What earlier precedents did the Court rely on or distinguish?
The Court relied on Nebbia's reasonableness framework and cited cases like Muller v. Oregon, Bunting v. Oregon, and Holden v. Hardy, which had upheld labor regulations. It rejected Adkins's attempt to distinguish minimum wage from maximum hours laws, concluding there is no constitutional difference between the two for due process purposes.