West Coast Hotel Co. v. Parrish
The Supreme Court upheld Washington State's minimum wage law for women, ruling that setting a wage floor to protect workers' health and well-being does not violate the Constitution's guarantee of liberty.
In doing so, the Court explicitly overruled its own 1923 decision striking down a similar minimum wage law in Washington, D.C., ending years of conflicting rulings on whether states could regulate wages for women workers.
“Liberty under the Constitution is thus necessarily subject to the restraints of due process, and regulation which is reasonable in relation to its subject and is adopted in the interests of the community is due process.”
The Court's core statement that constitutional liberty allows reasonable regulation in the public interest.
How it got here: A trial court ruled against Parrish, but the Washington Supreme Court reversed and upheld the wage law; the hotel appealed to the U.S. Supreme Court.
The Case in Depth
What happened
Elsie Parrish worked as a chambermaid at a hotel run by the West Coast Hotel Company in Washington State. She was paid less than the minimum wage the state had set for women workers under a 1913 law. She and her husband sued to recover the difference between what she was paid and the legally required minimum wage.
The question before the Court
Could Washington State require employers to pay women workers a minimum wage without violating their constitutional right to make their own contracts?
Why it matters
The ruling gave states clear constitutional authority to set minimum wages, opening the door to broader wage-and-hour regulation nationwide. It marked a turning point away from an era in which courts frequently struck down labor protections as violations of employers' and workers' freedom to contract, paving the way for New Deal-era labor legislation.
What changes now
The ruling is a final decision on the merits and let the Washington Supreme Court's judgment stand, meaning Elsie Parrish would recover her back wages. More broadly, by overruling Adkins v. Children's Hospital, the decision cleared the way for states and eventually Congress to enact minimum wage laws without running into the constitutional objections that had struck down similar laws in the preceding decades.
What this does not decide
The decision addresses minimum wage laws specifically for women workers under the facts and law before the Court; it does not itself resolve whether wage regulation covering men would be constitutional, though the majority's reasoning about liberty and reasonable regulation was later extended to workers generally.
Concurrences and dissents
How the Justices voted
Majority (1). Justice Hughes (author).
Dissent (4). Justice Sutherland (author), joined by Justice Van Devanter, Justice McReynolds, and Justice Butler.
Dissent — Justice Sutherland
“But to say, if that be intended, that the words of the Constitution mean today what they did not mean when written — that is, that they do not apply to a situation now to which they would have applied then — is to rob that instrument of the essential element which continues it in force”The dissent's objection to letting changing economic conditions influence constitutional interpretation.
Justice Sutherland, joined by three other justices, argued the Washington law was essentially identical to the D.C. law struck down in Adkins and should likewise be found unconstitutional. He maintained that the Constitution's meaning does not change with economic conditions, that freedom of contract for adult women who are legally equal to men cannot be arbitrarily restricted while leaving men free to bargain, and that a wage law ignoring the value of services rendered is an arbitrary taking from employers for essentially social welfare purposes. Read the full dissent →
How the Court got there
The legal reasoning, step by step
- The Court began by rejecting the idea that the Constitution protects an absolute freedom of contract; instead, liberty under the Due Process Clause is always subject to reasonable regulations adopted in the interest of the community's health, safety, and welfare.
- Applying this principle, the Court noted it had long allowed states to regulate employment contracts when there was unequal bargaining power between employers and employees, citing earlier rulings upholding maximum-hours laws and workplace safety rules.
- The Court found no meaningful constitutional difference between regulating maximum hours (already upheld) and regulating minimum wages, rejecting the earlier distinction drawn in Adkins v. Children's Hospital that treated wage-setting as fundamentally different from and less permissible than hour-setting.
- The Court reasoned that women workers, as a class with historically weaker bargaining power, were especially vulnerable to exploitative wages, and that protecting them from wages inadequate to meet basic living costs served a legitimate public interest, including preventing the public from having to subsidize underpaid workers through relief programs.
- Because the wage-setting process involved input from employers, employees, and the public, and included exceptions for less capable workers, the Court concluded the law was a reasonable, non-arbitrary exercise of the state's police power rather than an arbitrary taking from employers.
- Having concluded that Adkins rested on a flawed distinction and could not be reconciled with the Court's other precedents upholding protective labor legislation, the Court determined that Adkins should no longer control and that the reasoning it had used to invalidate wage laws for women was itself unsound.
Doctrinal impact
Cases affected by this decision
Overrules Adkins v. Children's Hospital (261 U.S. 525)
The Court explicitly overruled this 1923 decision that had struck down a minimum wage law as unconstitutional.
Limits Morehead v. New York ex rel. Tipaldo (298 U.S. 587)
The Court found the earlier ruling's reliance on Adkins no longer controlling since Adkins itself was overruled.