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West Coast Hotel Co. v. Parrish
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| West Coast Hotel Co. v. Parrish | |
| Reference: 300 U.S. 379 | |
| Term: 1937 | |
| Important Dates | |
| Argued: December 16-17, 1936 Decided: March 29, 1937 | |
| Outcome | |
| Washington Supreme Court affirmed | |
| Majority | |
| Charles E. Hughes • Louis Brandeis • Harlan Fiske Stone • Owen Josephus Roberts • Benjamin Nathan Cardozo | |
| Dissenting | |
| Willis Van Devanter • James Clark McReynolds • George Sutherland • Pierce Butler | |
West Coast Hotel v. Parrish is a case decided on March 29, 1937, by the United States Supreme Court holding that private employers had to accept a minimum wage for employees as established by the state of Washington. The case concerned whether it was constitutional for a state to enforce a minimum wage. The Supreme Court's decision in this case overturned Lochner v. New York.[1][2][3]
Why it matters: The Supreme Court's decision in this case established that the Constitution's freedom of contract does not prohibit states from establishing economic regulations. To read more about the impact of West Coast Hotel Co. v. Parrish click here.
Background
A 1932 Washington state law, "Minimum Wages for Women," was established with the goal to protect women and children from working conditions that were determined to have "pernicious effects on their health and morals." The state determined a suitable wage at $14.50 for a 48-hour work week.
Elsie Parrish worked as a chambermaid for West Coast Hotel. She sued the hotel for unpaid wages according to the established minimum wage. The hotel argued that the law was unconstitutional.[3]
Oral argument
Oral argument was held between December 16, 1936, and December 17, 1936. The case was decided on March 29, 1937.[1]
Decision
The Supreme Court decided 5-4 to affirm the decision of the Washington Supreme Court. Chief Justice Charles E. Hughes delivered the opinion of the court. Justice George Sutherland wrote a dissenting opinion.[2]
Opinions
Opinion of the court
Chief Justice Charles E. Hughes, writing for the court, argued that the state of Washington saw a need to protect an exploited class of workers and acted within their legislative authority to do so. Hughes contended that the legislation was therefore constitutional.[2]
| “ | There is an additional and compelling consideration which recent economic experience has brought into a strong light. The exploitation of a class of workers who are in an unequal position with respect to bargaining power, and are thus relatively defenceless against the denial of a living wage, is not only detrimental to their health and wellbeing, but casts a direct burden for their support upon the community. What these workers lose in wages, the taxpayers are called upon to pay. The bare cost of living must be met. We may take judicial notice of the unparalleled demands for relief which arose during the recent period of depression and still continue to an alarming extent despite the degree of economic recovery which has been achieved. It is unnecessary to cite official statistics to establish what is of common knowledge through the length and breadth of the land. While, in the instant case, no factual brief has been presented, there is no reason to doubt that the State of Washington has encountered the same social problem that is present elsewhere. The community is not bound to provide what is, in effect, a subsidy for unconscionable employers. The community may direct its lawmaking power to correct the abuse which springs from their selfish disregard of the public interest. The argument that the legislation in question constitutes an arbitrary discrimination, because it does not extend to men, is unavailing. This Court has frequently held that the legislative authority, acting within its proper field, is not bound to extend its regulation to all cases which it might possibly reach. The legislature 'is free to recognize degrees of harm and it may confine its restrictions to those classes of cases where the need is deemed to be clearest.' If 'the law presumably hits the evil where it is most felt, it is not to be overthrown because there are other instances to which it might have been applied.'[4] | ” |
| —Charles E. Hughes, majority opinion in West Coast Hotel Co. v. Parrish[2] | ||
Dissenting opinions
Justice George Sutherland dissented, arguing that the legislation enacted by the state of Washington was unconstitutional because it discriminated against men.[2]
| “ | An appeal to the principle that the legislature is free to recognize degrees of harm, and confine its restrictions accordingly, is but to beg the question, which is, since the contractual rights of men and women are the same, does the legislation here involved, by restricting only the rights of women to make contracts as to wages, create an arbitrary discrimination? We think it does. Difference of sex affords no reasonable ground for making a restriction applicable to the wage contracts of all working women from which like contracts of all working men are left free. Certainly a suggestion that the bargaining ability of the average woman is not equal to that of the average man would lack substance. The ability to make a fair bargain, as everyone knows, does not depend upon sex.
If, in the light of the facts, the state legislation, without reason or for reasons of mere expediency, excluded men from the provisions of the legislation, the power was exercised arbitrarily. On the other hand, if such legislation in respect of men was properly omitted on the ground that it would be unconstitutional, the same conclusion of unconstitutionality is inescapable in respect of similar legislative restraint in the case of women, 261 U.S. 261 U. S. 553.[4] |
” |
| —George Sutherland, dissenting opinion in West Coast Hotel Co. v. Parrish[2] | ||
Impact
| Federalism |
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| •Key terms • Court cases •Major arguments • State responses to federal mandates • Federalism by the numbers • Index of articles about federalism |
- See also: Adkins v. Children's Hospital and Lochner v. New York
This decision overruled Adkins v. Children's Hospital, creating the opportunity for a minimum wage to spread across the country.[1]
Because President Franklin Roosevelt was working to secure New Deal legislation by adding members to the Court who were against the Lochner v. New York ruling, some believed this Supreme Court decision was a political move. However, Roosevelt's announcement of his court-packing scheme came after the Supreme Court decision. There is some controversy over whether or not related politics played a role in the unexpected change in vote by Justice Owen Josephus Roberts.[3]
See also
External links
- Full text of case syllabus and opinions (Justia)
- Supreme Court of the United States
- Search Google News for this topic
Footnotes
- ↑ 1.0 1.1 1.2 Oyez, "West Coast Hotel Company v. Parrish," accessed July 26, 2022
- ↑ 2.0 2.1 2.2 2.3 2.4 2.5 Justia, "West Coast Hotel Co. v. Parrish, 300 U.S. 379 (1937)," accessed July 26, 2022
- ↑ 3.0 3.1 3.2 PBS, "Landmark Cases: West Coast Hotel v. Parrish", accessed December 13, 2013
- ↑ 4.0 4.1 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
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