West Coast Hotel Co. v. Parrish

Brief Fact Summary.

West Coast Hotel violated a state minimum wage law for women workers.

Synopsis of Rule of Law.

Minimum wage laws for women do not violate the Due Process Clause.

Facts.

Parrish was an employee at the West Coast Hotel. The hotel paid her less than they were required to under Washington’s minimum wage law for women workers.

Issue.

Did Washington’s mandatory minimum wage law for women violate the Due Process Clause?

Held.

No, Washington’s mandatory minimum wage law for women did not violate the Due Process Clause.

Dissent.

Justice Sutherland

Justice Sutherland argued that the law unnecessarily discriminated between men and women, and was thus arbitrary.

Discussion.

The Supreme Court found that the protection of women was a legitimate goal of the state, and that establishing a minimum wage for women workers was an admissible means to that end. The Supreme Court held that the Due Process Clause protects liberty, not the freedom of contract, and that even the protection of liberty is subject to restraint.

The Supreme Court also overruled Adkins v. Children’s Hospital. In Adkins, the Supreme Court invalidated a minimum wage law as a violation of due process, recognizing a freedom of contract.