Adkins v. Children's Hospital of Columbia

Background

A federal law passed in 1918 created a three-member Minimum Wage Board for the District of Columbia to investigate wages, hold hearings, and set minimum wages for women and minors. A children’s hospital and a 21-year-old elevator operator challenged the Board’s orders after some agreed wages fell below its minimums. The employers and the woman sued to stop enforcement, and lower courts ultimately entered permanent injunctions declaring the statute unconstitutional.

Reasoning

The central question was whether Congress could authorize a board to fix minimum wages for adult women in the District. The majority, writing through Justice Sutherland, said the law unconstitutionally interfered with the Fifth Amendment liberty to make private contracts. The Court described the law as a form of price-fixing that used vague standards—cost of living, health, and morals—and allowed the Board to set wages without regard to individual circumstances or an employer’s ability to pay. That, the Court found, was an arbitrary intrusion on the freedom of employers and workers to agree on wages and went beyond the police power that can justify limits on hours or special protections for certain occupations.

Real world impact

The decision invalidates the 1918 statute and prevents the Board from enforcing its minimum-wage orders in the District of Columbia. Employers and adult women in the District may continue to make private wage agreements without the Board’s price-setting power. The opinion also signals limits on similar federal wage-fixing schemes and frames how courts will assess federal and state labor regulations going forward.

Dissents or concurrances

Chief Justice Taft and Justice Holmes dissented. They argued Congress could use its police power to protect health and morals, that minimum wages are akin to valid labor-hour limits, and that reasonable legislatures could adopt such measures.