West Coast Hotel Co. v. Parrish

West Coast Hotel Co. v. Parrish

Argued December 16–17, 1936
Decided March 29, 1937
Full case name West Coast Hotel Company v. Elsie Parrish, et ux.
Citations

300 U.S. 379 (more)

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
Prior history Judgment for defendant, Chelan County Superior Court, November 9, 1935; reversed, 55 P.2d 1083 (Wash. 1936)
Subsequent history None
Holding
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.
Court membership
Chief Justice
Charles E. Hughes
Case opinions
Majority Hughes, joined by Brandeis, Stone, Roberts, Cardozo
Dissent Sutherland, joined by Van Devanter, McReynolds, Butler
Laws applied
U.S. Const. amend. XIV; Minimum Wages for Women Act, 1913 Wash. Laws 174
This case overturned a previous ruling or rulings
Adkins v. Children's Hospital (1923)

West Coast Hotel Co. v. Parrish, 300 U.S. 379 (1937), 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, 261 U.S. 525 (1923). 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.[1]

Facts

Elsie Parrish, a chambermaid working at the Cascadian Hotel in Wenatchee, Washington (owned by the West Coast Hotel Company), along with her husband, sued the hotel for the difference between what she was paid, and the $14.50 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.

Judgment

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. Chief Justice Hughes said the following.

“ The principle which must control our decision is not in doubt. The constitutional provision invoked is the due process clause of the Fourteenth Amendment governing the states, as the due process clause invoked in the Adkins Case governed Congress. In each case the violation alleged by those attacking minimum wage regulation for women is deprivation of freedom of contract. What is this freedom? The Constitution does not speak of freedom of contract. It speaks of liberty and prohibits the deprivation of liberty without due process of law. In prohibiting that deprivation, the Constitution does not recognize an absolute and uncontrollable liberty. Liberty in each of its phases has its history and connotation. But the liberty safeguarded is liberty in a social organization which requires the protection of law against the evils which menace the health, safety, morals, and welfare of the people. Liberty under the Constitution is thus necessarily subject to the restraints of due process, and regulation which is reasonable in relation to its subject and is adopted in the interests of the community is due process.

This essential limitation of liberty in general governs freedom of contract in particular. More than twenty-five years ago we set forth the applicable principle in these words, after referring to the cases where the liberty guaranteed by the Fourteenth Amendment had been broadly described.[2]

'But it was recognized in the cases cited, as in many others, that freedom of contract is a qualified, and not an absolute, right. There is no absolute freedom to do as one wills or to contract as one chooses. The guaranty of liberty does not withdraw from legislative supervision that wide department of activity which consists of the making of contracts, or deny to government the power to provide restrictive safeguards. Liberty implies the absence of arbitrary restraint, not immunity from reasonable regulations and prohibitions imposed in the interests of the community.' Chicago, Burlington & Quincy R. Co. v. McGuire, 219 U.S. 549, 565, 31 S.Ct. 259, 262, 55 L.Ed. 328.

This power under the Constitution to restrict freedom of contract has had many illustrations. That it may be exercised in the public interest with respect to contracts between employer and employee is undeniable.

[...]

We think that the views thus expressed are sound and that the decision in the Adkins Case was a departure from the true application of the principles governing the regulation by the state of the relation of employer and employed. Those principles have been reenforced by our subsequent decisions.

 ”

Significance

Muller v. Oregon was one of the few exceptions to 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 an unexpected shift in the voting habit of Associate Justice Roberts, who had previously joined the four conservative justices in striking down a similar minimum wage law in New York in the 1936 case Morehead v. New York ex rel. Tipaldo.[3] 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 showed that Roberts had voted in favor of Washington State's minimum wage on December 19, 1936,[4] just two days after oral arguments concluded,[5] and that the court was divided, 4–4, at this time only because pro-New Deal Associate Justice Harlan Fiske Stone was absent due to an illness.[5] Chief Justice Hughes stated in his autobiographical notes that Roosevelt's attempt to pack the court "had not the slightest effect on our [the court's] decision" and that the delay in the ruling, which was caused only by Stone's absence,[4] led to false speculation that Roosevelt's court-packing proposal successfully intimidated the court into ruling in favor of Washington's minimum wage law.[4] Hughes and Roberts also both acknowledged that because of the overwhelming support that had been shown for the New Deal through Roosevelt's re-election in November 1936,[6] Hughes was able to persuade Roberts to no longer base his votes on his own political beliefs and side with him during future votes on New Deal related policies[6][7] In one of his notes from 1936, Hughes wrote that Roosevelt's re-election forced the court to depart from "its fortress in public opinion" and severely weakened its capability to base its rulings on personal or political beliefs.[6]

Roberts' move was notoriously referred to as "the switch in time that saved nine." Shortly after leaving the Court, Roberts reportedly burned all of his legal and judicial papers. As a result, there is no significant collection of Roberts' manuscript papers, as there is for most other modern Justices. Roberts did prepare a short memorandum discussing his alleged change of stance around the time of the court-packing effort, which he left in the hands of Justice Felix Frankfurter.[8] 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).

See also

Notes

  1. ↑ Philips, Michael J. (2001). The Lochner Court, Myth and Reality: Substantive Due Process from the 1890s to the 1930s. Greenwood. p. 10. ISBN 0-275-96930-4.
  2. ↑ Allgeyer v. Louisiana, 165 U.S. 578, 17 S.Ct. 427, 41 L.Ed. 832; Lochner v. New York, 198 U.S. 45, 25 S.Ct. 539, 49 L.Ed. 937, 3 Ann.Cas. 1133; Adair v. United States, 208 U.S. 161, 28 S.Ct. 277, 52 L.Ed. 436, 13 Ann.Cas. 764.
  3. ↑ Lorant, Stefan (1968). The Glorious Burden: The American Presidency. New York, Harper and Row. p. 628. ISBN 9780060126865.
  4. 1 2 3 McKenna, Marian C. (2002). Franklin Roosevelt and the Great Constitutional War: The Court-packing Crisis of 1937. New York, NY: Fordham University Press. p. 419. ISBN 978-0-8232-2154-7.
  5. 1 2 McKenna, Marian C. (2002). Franklin Roosevelt and the Great Constitutional War: The Court-packing Crisis of 1937. New York, NY: Fordham University Press. p. 414. ISBN 978-0-8232-2154-7.
  6. 1 2 3 Devins, Neal (1996). "Government Lawyers and the New Deal". William & Mary Law School. Retrieved October 15, 2013.
  7. ↑ McKenna, Marian C. (2002). Franklin Roosevelt and the Great Constitutional War: The Court-packing Crisis of 1937. New York, NY: Fordham University Press. pp. 422–23. ISBN 978-0-8232-2154-7.
  8. ↑ Roberts, Justice Owen J. (November 9, 1945). "Roberts Memorandum". New Deal Network. Retrieved July 8, 2012.

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