West Coast Hotel Co. v. Parrish
Headline: State minimum-wage law for women is upheld, overruling prior limits and forcing employers to pay required minimums, making it easier for female workers to secure a living wage and harder for low-paying employers to avoid responsibility.
Holding: The Court unanimously upheld Washington’s minimum-wage law for women, reversing Adkins and ruling that states may set reasonable minimum wages to protect workers’ health and welfare, so the hotel must pay the statutory minimum.
- Allows states to set and enforce minimum wages for women.
- Requires employers to pay statutory minimums set through the commission process.
- Strengthens state power to address low-wage exploitation of workers.
Summary
Background
A hotel owner refused to pay a higher wage required by Washington’s “Minimum Wages for Women” law, and a chambermaid, Elsie Parrish, sued to recover the difference. The state law set a minimum wage ($14.50 per week for 48 hours) and created a commission to investigate industries and set wages for women and minors. The hotel argued the law violated the Fourteenth Amendment by interfering with freedom of contract.
Reasoning
The Court reconsidered an earlier decision that had struck down a similar wage law and concluded that freedom of contract is not absolute. The majority said states may use their power to protect health, safety, morals, and welfare, and that reasonable minimum-wage rules set after hearings and with employer and worker input are valid. The Court relied on prior cases upholding workplace regulations and noted recent economic hardships as a reason to allow protective laws. The judgment upholding the Washington law was affirmed.
Real world impact
The decision allows states to maintain and enforce minimum wages set to protect workers’ health and welfare. Employers subject to such state laws must pay the statutory minimums established through the regulatory process. The ruling also rejects the earlier national obstacle to minimum-wage laws, so similar state protections remain in effect and gain stronger backing from the Court.
Dissents or concurrances
A dissent argued that the Constitution’s meaning does not change with economic conditions, that judges must enforce earlier limits on wage regulation, and that the Washington law arbitrarily discriminates and unduly restricts freedom of contract.
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