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March 14
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1923
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April 9
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1923
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Adkins et al, constituting the Minimum Wage Board of the District of Columbia v Children's Hospital of the District of Columbia same v Willie Lyons
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261
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525
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43 S Ct 394 67 L Ed 785 1923 US LEXIS 2588 24 ALR 1238
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Dismissed, DC Supreme Court reversed and remanded, 284 F 613 (DC Cir 1922)
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None
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Minimum wage law for women violated the due process right to contract freely DC Court of Appeals affirmed
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1923-1925
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Sutherland
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McKenna, Van Devanter, McReynolds, Butler
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Taft
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Sanford
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Holmes
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Brandeis_
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US Const Amends V , XIX Minimum Wage Law of the District of Columbia, 40 Stat 960 (1918)
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''West Coast Hotel Co v Parrish'', 300 US 379 (1937)
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'', , is a
Supreme Court opinion holding that federal minimum wage legislation for women was an unconstitutional infringement of liberty of contract, as protected by the
Fifth Amendment . The Court opinion, by Justice
Sutherland , held that previous decisions (''
Muller V. Oregon '', 208 U.S. 412 (1908) and ''
Bunting V. Oregon '', 243 U.S. 426 (1917)) did not overrule the holding in ''
Lochner V. New York '', 198 U.S. 45 (1905), protecting
Freedom Of Contract . The ''Muller'' cases, Sutherland noted, addressed maximum hours; this case addressed a minimum wage. The maximum hour laws left the parties free to negotiate about wages, unlike this law. Moreover, the minimum wage artificially restricts the employer’s side of the negotiation. The Court argued that if legislatures were permitted to set minimum wage laws, they would be permitted to set maximum wage laws.
Chief Justice Taft , dissenting, argued that there was no distinction between minimum wage laws and maximum hour laws, considering that these essentially both add up to restrictions on the contract. He noted that ''Lochner''’s limitations had appeared to be overruled in Muller and Bunting.
Justice
Holmes , also dissenting, noted that there were plenty of other constraints on contract (e.g. blue laws, usury laws, etc.). He cited the reasonable person standard he had put forth in ''Lochner'': if a reasonable person could see a power in the Constitution, the Court ought to defer to legislation using that power.
''Adkins'' was overturned in ''
West Coast Hotel Co. V. Parrish '', 300 U.S. 379 (
1937 ).
- Zimmerman, J. G. (1991). The jurisprudence of equality: the women's minimum wage, the first Equal Rights Amendment, and Adkins v. Children's Hospital, 1905-1923. The Journal of American History, Vol. 78, No. 1. (Jun., 1991), pp. 188-225.
