West Coast Hotel Co. v. Parrish

Following is the case brief for West Coast Hotel Co. v. Parrish, 300 U.S. 379 (1937)

Case Summary of West Coast Hotel Co. v. Parrish:

  • The State of Washington passed a minimum wage law for women (and minors).
  • Elsie Parrish worked as a housekeeper in the West Coast Hotel.  The Hotel did not pay Parrish the statutory minimum wage.
  • Parrish sued for recovery of the wages she should have earned.
  • Reversing the trial court, the Supreme Court of Washington upheld the statute and found for Parrish.
  • The U.S. Supreme Court affirmed, finding that the State has a special interest in protecting wages for women who are particularly vulnerable to unscrupulous employers.

West Coast Hotel Co. v. Parrish Case Brief

Statement of the Facts:

The State of Washington passed a law that established a minimum wage for women and minors.  Elsie Parrish, who worked as a housekeeper in the West Coast Hotel, sued because the Hotel did not pay her the minimum wage in accordance with the statute.  The Hotel argued that the minimum wage statute violated the Due Process Clause of the Fourteenth Amendment, given that it was an encroachment on the liberty to contract.

Procedural History:

  • The trial court found for the Hotel owner.
  • The Supreme Court of Washington, however, reversed. It stated that the statute was valid and ordered the appropriate compensation for Parrish.
  • The U.S. Supreme Court heard the appeal filed by the Hotel owner.

Issue and Holding:

Does a minimum wage law for women and minors violate the Due Process Clause of the Fourteenth Amendment?  No.

Judgment:

The decision of the Supreme Court of Washington is affirmed.

Rule of Law or Legal Principle Applied:

Due process is not violated when a State enacts a minimum wage law for women.

Reasoning:

Due process is not violated when the freedom to contract is limited to protect the community against harm to health, safety, morals, or the welfare of the people.  Reasonable regulations have been allowed when they ensure wholesome conditions of work and freedom from oppression.

With regard to women in particular, the State has a special interest in protecting them from being disadvantaged by employment contracts resulting in bad working conditions, long hours, and low wages.  That is because women’s health is important, they are more susceptible to exploitation by unscrupulous employers, and denying women a living wage puts a burden on the community to support them.

Because other cases of the Court previously struck down State minimum wage laws for women, the Court is compelled to revisit those cases.  As a consequence, Adkins v. Children’s Hospital, 261 U.S. 525 is overruled, and Morehead v. New York ex rel. Tipaldo, 298 U.S. 587 is distinguished.

Concurring and Dissenting Opinions:

Dissenting Opinion (Sutherland):

The Court’s adherence to precedent is very important to the credibility of the Court, and should not be ignored on a whim.  The reasons why the minimum wage law for women should be struck down is explained at length in the Court’s opinions in Adkins and Morehead.

Significance:

West Coast Hotel Co. v. Parrish is a significant case because it marked an end to the Lochner era of the Supreme Court, during which the Court struck down any limitation on a business’ ability to contract.  The Lochner case in particular is a good example of the Court turning a blind eye to the obvious reality that employers and employees are not on equal footing when it comes to employment contracts.   West Coast Hotel Co. v. Parrish specifically mentions that lack of equality in employment negotiations.

Student Resources:

Read the Full Court Opinion

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