West Coast Hotel Co. v. Parrish
From Judgepedia
| West Coast Hotel Co. v. Parrish | |
 | |
| Supreme Court of the United States | |
| Full case name | West Coast Hotel Company v. Ernest Parrish, et ux. |
|---|---|
| Date decided | March 29, 1937 |
| Citations | 300 U.S. 379; 57 S. Ct. 578; 81 L. Ed. 703; 1937 U.S. LEXIS 1119; 1 Lab. Cas. (CCH) P17,021; 8 Ohio Op. 89; 108 A.L.R. 1330; 1 L.R.R.M. 754; 7 L.R.R.M. 754 |
| Judges sitting | Chief Justice: Charles E. Hughes Associate Justices: Willis Van Devanter, James C. McReynolds, Louis Brandeis, George Sutherland, Pierce Butler, Harlan F. Stone, Owen J. Roberts, Benjamin N. Cardozo |
| Case history | |
| Prior actions | Judgment for defendant, Chelan County Superior Court, Nov. 9, 1935; reversed, 55 P.2d 1083 (Wash. 1936) |
| Case opinions | |
| 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. | |
Contents |
West Coast Hotel Co. v. Parrish 300 U.S. 379 (1937), was a monumental Supreme Court ruling that functionally ended the Lochner era in freedom of contract cases.
Background
Ethel Parrish, the plaintiff was a hotel worker working at a hotel owned by West Coast Hotel. Under Washington Law, as established byIndustrial Welfare Committee and Supervisor of Women in Industry, the minumum wage for a woman working 48hrs a week was $14.50 per week. At the end of her contract, Parrish sued West Coast Hotel for the difference between the established minimum wage, and the amount she was paid. West Coast Hotel offered to pay her $17 for her services, and the actual difference was $216.19. The trial court used the precedent established in Adair v. United States ruling that the minimum wage law was an unconstitutional limitation on the freedom of contract.
Issue
The main issue in Parish is whether or not the Washington minimum wage law was an unconstitutional limitation on the freedom of contract, or whether there was a special state interest in protecting health of workers in regulating minimum wage.
Holding
Washington's minimum wage law was a legitimate exercise of regulation because there was a special state interest in protecting the health of workers, and the minimum wage law was established for that purpose.
Legal Reasoning
The ruling was a 5-4 decision in favor of Parrish. The opinion, written by Chief Justice Hughes, restriction of liberty of contract by state law is a legitimate function of government, 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 supreme court upheld a law regulating the working hours of women.
This case expanded upon the the health and safty interst of the state to where minimum wage laws would not be challenged after Parrish. This functionally ended the Lochnerera. The case also had a large political effect. At the time, the Supreme Court used the freedom of contract reasoning to overturn much of the New Deal legislation proposed by President Roosevelt. Roosevelt had proposed his "court reform bill" to increase the size of the Supreme Court to where he would have a majority of justices in his side. The change in vote by Associate Justice Owen Roberts, had the effect of making the purpose of the court reform bill moot, and it eventually died in congress.
