West Coast Hotel Co. v. Parrish
300 U.S. 379 (1937)
Washington State enacted a law
creating a minimum wage for women and children. Parrish worked at West
Coast Hotel, and sued to recover the difference between the wages they
paid her, and the minimum wage.
West Coast pointed to Adkins
v. Children's Hospital (261 U.S. 525
(1923)), where a Federal law establishing a minimum wage in Washington DC
was found to be unconstitutional because it interfered with the freedom
of contract included within the Due Process Clause of the 5th Amendment.
West Coast also pointed to Morehead
v. New York ex re. Tipaldo (298 U.S.
587 (1936)), where a State minimum wage law was overturned on the idea
that setting a minimum wage fell outside of a State's police powers
because it did not serve a valid State purpose.
The US Supreme Court
overturned Adkins and Morehead and found minimum wage laws to be
The US Supreme Court found
that the minimum wage law was a valid regulation freedom of contract because of the State's special interest in
protecting women's health and ability to support themselves.
The Court expanded on the
idea that that government can interfere with freedom of contract only to serve a valid police purpose of protecting public health, public safety or
public morals. In this case they extended it to the protection of
specific vulnerable groups (women and children).
Note that the shift of the
Court in this case is reflective of the shift between the laissez-faire
philosophy of the early 20th Century, and the realities of the
Great Depression of the 1930s.
Cf. Lochner v. New York (198 U.S. 45 (1905)), which was also conceptually
overturned by this decision.
At this time, the Court
hadn't explicitly defined terms such as strict scrutiny and rational basis, but this case can be thought of as one in
which the Court changed their mind and decided that rational
basis is the proper standard of
review for economic regulations (Lochner basically held it
was strict scrutiny).
See United States v.
Carolene Products Co. (304 U.S. 144