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December 16
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| |
17
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1936
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March 29
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1937
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West Coast Hotel Company v Ernest Parrish, et ux
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300
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379
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57 S Ct 578 81 L Ed 703 1937 US LEXIS 1119 1 Lab Cas (CCH) P17,021 8 Ohio Op 89 108 ALR 1330 1 LRRM 754 7 LRRM 754
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Judgment for defendant, Chelan County Superior Court , Nov 9, 1935 reversed, 55 P2d 1083 ( Wash 1936)
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None
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Washington's minimum wage law for women was a valid regulation of the right to contract freely because of the state's special interest in protecting their health and ability to support themselves Supreme Court of Washington affirmed
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1932-1937
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Hughes
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Brandeis, Stone, Roberts, Cardozo
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Sutherland
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Van Devanter, McReynolds, Butler
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US Const Amend XIV Minimum Wages for Women Act, 1913 Wash Laws 174
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'',
300 U.S. 379 (
1937 ), was a decision by the
Supreme Court Of The United States that upheld the constitutionality of
Minimum Wage legislation enacted by the State of
Washington , overturning an earlier decision in ''
Adkins V. Children's Hospital '', 261 U.S. 525 (
1923 ).
The Court, in an opinion by
Chief Justice Hughes , ruled that the Constitution permitted the restriction of liberty of contract by state law where such restriction protected the community, health and safety or vulnerable groups, as in the case of ''
Muller V. Oregon '', 208 U.S. 412 (
1908 ), where the Court had found in favor of the regulation of women's working hours.
''Muller'', however, was one of the few exceptions of decades of Court invalidation of economic regulation, exemplified in ''
Lochner V. New York '', 198 U.S. 45 (
1905 ). ''West Coast Hotel'' represents the end of that trend, and came about through a sudden and seemingly inexplicable shift in the voting habits of
Justice Roberts . Coming as it did right when President
Franklin D. Roosevelt was pushing his "court packing" scheme to weaken the votes of the older anti-
New Deal justices, Roberts' move was notoriously referred to as "
The Switch In Time That Saved Nine ," even though Roberts decision was handed in before Roosevelt actually had made his plan public.
Justice
Sutherland 's dissent contained a thinly veiled admonition to Roberts for switching sides, as well as an insistence that the Constitution does not change by events alone (namely, the
Great Depression ). The dissent also adhered to the previously dominant perspective that the majority repudiated here: that freedom of contract was the rule with few exceptions, and that the shift of the burden for the poor onto employers was an arbitrary and naked exercise of power.
Although the majority's view on economic regulation remains the law of the land today, the expansion of
Commerce Clause jurisprudence signaled by ''West Coast Hotel'' was reined in slightly by ''
United States V. Lopez '', 514 U.S. 549 (
1995 ), and ''
United States V. Morrison '', 529 U.S. 598 (
2000 ).
John Ryskamp, ''The Eminent Domain Revolt: Changing Perceptions in a New Constitutional Epoch,'' New York: Algora Publishing, 2006.
