West Coast Hotel Co. v. Parrish (Minimum wage, 1937)
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Overview
Overview
The Supreme Court upheld Washington's minimum wage law for women, overruling Lochner-era jurisprudence protecting freedom of contract.
The Facts
Facts
Elsie Parrish, a hotel chambermaid, sued West Coast Hotel Co. for unpaid wages under Washington's minimum wage statute requiring employers to pay women at least the minimum wage. The hotel argued the law violated the Due Process Clause of the Fourteenth Amendment by interfering with freedom of contract. Washington's courts upheld the statute, and the case reached the U.S. Supreme Court.
The Issue
Issue
Whether the Fourteenth Amendment's Due Process Clause permits a state to enact minimum wage legislation for women, and whether such legislation represents a permissible exercise of the state's police power to protect public health and safety.
The Rules
Rule
West Coast Hotel Co. v. Parrish, 300 U.S. 379 (1937), upheld Washington's minimum wage law for women as a valid exercise of state police power and expressly repudiated Lochner v. New York's substantive due process protection of freedom of contract in the economic sphere. The decision signaled the end of the Lochner era and the Court's abandonment of heightened scrutiny for economic regulation, accepting the legislature's reasonable judgment about worker welfare without requiring strict justification.
The Application
Analysis
The Court applied its new rational basis standard to Washington's minimum wage statute and found that the law was rationally related to the legitimate state purpose of protecting vulnerable workers from exploitative wages and working conditions. A conclusion previously foreclosed by Lochner's heightened protection of freedom of contract. In examining Parrish's claim, the Court focused not on whether the employer and employee had a constitutional right to negotiate any wage they wished, but instead on whether the legislature could reasonably conclude that a statutory minimum protected women workers' health and welfare. The Court upheld the statute because the state's judgment that economic regulation was necessary to protect a vulnerable class was reasonable and within the legislature's competence to make, abandoning the notion that courts should second-guess such economic policy choices on constitutional grounds. This application directly reversed the precedent that had invalidated similar legislation, signaling that economic regulations would receive only rational basis review.
The Conclusion
Conclusion
The Supreme Court upheld the minimum wage law in a 5-4 decision, holding that states have broad authority to regulate economic affairs and working conditions to protect vulnerable workers. The Court rejected the Lochner doctrine's rigid application of freedom of contract, establishing that economic regulations need only be rationally related to a legitimate state purpose. This decision marked a pivotal shift away from substantive due process limitations on economic legislation.
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