West Coast Hotel Co. v. Parrish
Encyclopedia
West Coast Hotel Co. v. Parrish, , was a decision by the United States Supreme Court
upholding the constitutionality of minimum wage
legislation enacted by the State of Washington, overturning an earlier decision in Adkins v. Children's Hospital
, . The decision is usually regarded as having ended the Lochner era
, a period in American legal history during which the Supreme Court tended to invalidate legislation aimed at regulating business.
(owned by the West Coast Hotel Company), along with her husband
, sued the hotel
for the difference between what she was paid, and the $14.30 per week of 48 hours established as a minimum wage
by the Industrial Welfare Committee and Supervisor of Women in Industry, pursuant to Washington state law. The trial court, using Adkins as precedent, ruled for the defendant. The Washington Supreme Court
, taking the case on a direct appeal, reversed the trial court and found in favor of Parrish. The hotel appealed to the U.S. Supreme Court.
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
, , where the Court had found in favor of the regulation of women's working hours.
The Muller case, however, was one of the few exceptions to decades of Court invalidation of economic regulation, exemplified in Lochner v. New York
, . West Coast Hotel represents the end of that trend, and came about through an unexpected shift in the voting habit of Associate Justice
Roberts
. Coming shortly after President Franklin D. Roosevelt
had proposed his court reform bill
to weaken the votes of the older, anti-New Deal
justices, although the historical record lends weight to assertions that Roberts' decision happened much earlier, Roberts' move was notoriously referred to as "the switch in time that saved nine
."
Associate Justice Sutherland
's dissent contained a thinly veiled admonition of Roberts, as well as an insistence that the Constitution is not subject to the perceived necessities of present-day events (namely, the Great Depression
). The dissent also adhered to the previously dominant perspective that the majority repudiated: 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.
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
upholding the constitutionality of minimum wage
Minimum wage
A minimum wage is the lowest hourly, daily or monthly remuneration that employers may legally pay to workers. Equivalently, it is the lowest wage at which workers may sell their labour. Although minimum wage laws are in effect in a great many jurisdictions, there are differences of opinion about...
legislation enacted by the State of Washington, overturning an earlier decision in Adkins v. Children's Hospital
Adkins v. Children's Hospital
Adkins v. Children's Hospital, , 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 due process clause of the Fifth Amendment....
, . The decision is usually regarded as having ended the Lochner era
Lochner era
The Lochner era is a period in American legal history in which the Supreme Court of the United States tended to strike down laws held to be infringing on economic liberty or private contract rights, and takes its name from a 1905 case, Lochner v. New York. The beginning of the period is usually...
, a period in American legal history during which the Supreme Court tended to invalidate legislation aimed at regulating business.
Facts
Elsie Parrish, a chambermaid working at the Cascadian Hotel in Wenatchee, WashingtonWenatchee, Washington
Wenatchee is located in North Central Washington and is the largest city and county seat of Chelan County, Washington, United States. The population within the city limits in 2010 was 31,925...
(owned by the West Coast Hotel Company), along with her husband
Husband
A husband is a male participant in a marriage. The rights and obligations of the husband regarding his spouse and others, and his status in the community and in law, vary between cultures and has varied over time...
, sued the hotel
Hotel
A hotel is an establishment that provides paid lodging on a short-term basis. The provision of basic accommodation, in times past, consisting only of a room with a bed, a cupboard, a small table and a washstand has largely been replaced by rooms with modern facilities, including en-suite bathrooms...
for the difference between what she was paid, and the $14.30 per week of 48 hours established as a minimum wage
Minimum wage
A minimum wage is the lowest hourly, daily or monthly remuneration that employers may legally pay to workers. Equivalently, it is the lowest wage at which workers may sell their labour. Although minimum wage laws are in effect in a great many jurisdictions, there are differences of opinion about...
by the Industrial Welfare Committee and Supervisor of Women in Industry, pursuant to Washington state law. The trial court, using Adkins as precedent, ruled for the defendant. The Washington Supreme Court
Washington Supreme Court
The Washington Supreme Court is the highest court in the judiciary of the U.S. state of Washington. The Court is composed of a Chief Justice and eight Justices. of the Court are elected to six-year terms...
, taking the case on a direct appeal, reversed the trial court and found in favor of Parrish. The hotel appealed to the U.S. Supreme Court.
Judgment
The Court, in an opinion by Chief JusticeChief Justice of the United States
The Chief Justice of the United States is the head of the United States federal court system and the chief judge of the Supreme Court of the United States. The Chief Justice is one of nine Supreme Court justices; the other eight are the Associate Justices of the Supreme Court of the United States...
Hughes
Charles Evans Hughes
Charles Evans Hughes, Sr. was an American statesman, lawyer and Republican politician from New York. He served as the 36th Governor of New York , Associate Justice of the Supreme Court of the United States , United States Secretary of State , a judge on the Court of International Justice , and...
, 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
Muller v. Oregon
Muller v. Oregon, , was a landmark decision in United States Supreme Court history, as it justifies both sex discrimination and usage of labor laws during the time period...
, , where the Court had found in favor of the regulation of women's working hours.
The Muller case, however, was one of the few exceptions to decades of Court invalidation of economic regulation, exemplified in Lochner v. New York
Lochner v. New York
Lochner vs. New York, , was a landmark United States Supreme Court case that held a "liberty of contract" was implicit in the due process clause of the Fourteenth Amendment. The case involved a New York law that limited the number of hours that a baker could work each day to ten, and limited the...
, . West Coast Hotel represents the end of that trend, and came about through an unexpected shift in the voting habit of Associate Justice
Associate Justice of the Supreme Court of the United States
Associate Justices of the Supreme Court of the United States are the members of the Supreme Court of the United States other than the Chief Justice of the United States...
Roberts
Owen Josephus Roberts
Owen Josephus Roberts was an Associate Justice of the United States Supreme Court for fifteen years. He also led the fact-finding commission that investigated the attack on Pearl Harbor. At the time of World War II, he was the only Republican appointed Judge on the Supreme Court of the United...
. Coming shortly after President Franklin D. Roosevelt
Franklin D. Roosevelt
Franklin Delano Roosevelt , also known by his initials, FDR, was the 32nd President of the United States and a central figure in world events during the mid-20th century, leading the United States during a time of worldwide economic crisis and world war...
had proposed his court reform bill
Judiciary Reorganization Bill of 1937
The Judicial Procedures Reform Bill of 1937, frequently called the court-packing plan, was a legislative initiative proposed by U.S. President Franklin Roosevelt to add more justices to the U.S. Supreme Court. Roosevelt's purpose was to obtain favorable rulings regarding New Deal legislation that...
to weaken the votes of the older, anti-New Deal
New Deal
The New Deal was a series of economic programs implemented in the United States between 1933 and 1936. They were passed by the U.S. Congress during the first term of President Franklin D. Roosevelt. The programs were Roosevelt's responses to the Great Depression, and focused on what historians call...
justices, although the historical record lends weight to assertions that Roberts' decision happened much earlier, Roberts' move was notoriously referred to as "the switch in time that saved nine
The switch in time that saved nine
“The switch in time that saved nine” is the name given to what was perceived as the sudden jurisprudential shift by Associate Justice Owen J. Roberts of the U.S. Supreme Court in West Coast Hotel Co. v. Parrish...
."
Associate Justice Sutherland
George Sutherland
Alexander George Sutherland was an English-born U.S. jurist and political figure. One of four appointments to the Supreme Court by President Warren G. Harding, he served as an Associate Justice of the U.S...
's dissent contained a thinly veiled admonition of Roberts, as well as an insistence that the Constitution is not subject to the perceived necessities of present-day events (namely, the Great Depression
Great Depression
The Great Depression was a severe worldwide economic depression in the decade preceding World War II. The timing of the Great Depression varied across nations, but in most countries it started in about 1929 and lasted until the late 1930s or early 1940s...
). The dissent also adhered to the previously dominant perspective that the majority repudiated: 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.