Q1: What area of law does West Coast Hotel Co. v. Parrish primarily address?
Constitutional Law
Q2: What was the central legal issue in West Coast Hotel Co. v. Parrish?
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?
Q3: What rule did the court apply?
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.
Q4: What was the court's holding?
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.
Q5: Why is West Coast Hotel Co. v. Parrish 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.