Adkins v. Children’s Hospital
Adkins v. Children’s Hospital is a landmark Supreme Court case from 1923 that addressed the intersection of workers' rights and the constitutional principle of freedom of contract. The case emerged when Congress established a minimum wage law for women and minors in the District of Columbia, aimed at protecting these vulnerable groups from poverty. However, Children's Hospital, which paid its employees below this minimum wage, challenged the law, arguing it violated the due process clause of the Fifth Amendment. The Supreme Court ruled in favor of the hospital in a 6-3 decision, asserting that the law infringed upon the right to freely contract. Justice George Sutherland, writing for the majority, emphasized the importance of freedom of contract and suggested that the minimum wage law was demeaning to women, particularly in light of their political equality post-Nineteenth Amendment.
The dissent, led by Chief Justice William H. Taft, contended that there was no significant distinction between regulating work hours and wages and cautioned against overturning laws based on perceived economic unwise or unsound theories. This case set a precedent that would later be revisited in subsequent rulings, reflecting ongoing debates about labor rights and economic regulation in the United States.
Adkins v. Children’s Hospital
Date: April 9, 1923
Citation: 261 U.S. 525
Issue: Minimum-wage laws
Significance: This decision, in which the Supreme Court struck down a minimum-wage law, was a prime example of the Court’s commitment to the freedom of contract doctrine and laissez-faire principles.
In 1918 Congress established a board with authority to set minimum wages for women and minors in the District of Columbia. The stated purpose of the law was to protect women and minors from conditions of poverty that would be “detrimental to their health and morals.” Children’s Hospital, a private institution paying less than the minimum wage, argued that the law was a violation of the due process clause of the Fifth Amendment. In a 6-3 vote, the Supreme Court agreed with the hospital’s position. Justice George Sutherland, speaking for the majority, based the ruling on two doctrines: substantive due process and freedom of contract. Although the government could exercise its police power to prevent specific evils, freedom of contract was “the general rule and restraint the exception.” Sutherland found that the law was demeaning to women, especially in view of the political equality that had resulted from the Nineteenth Amendment. In addition, any law that considered only the needs of workers was unjust to the needs of the employer.
Chief Justice William H. Taft,usually a defender of substantive due process, dissented in the Adkins case. He emphasized that the Court had earlier approved of laws mandating a maximum-hour workday and a time-and-a-half provision for overtime, and he argued that there were no fundamental differences between regulations of hours and of wages. He insisted that the Court should not overturn laws that were simply considered to be based on “unwise or unsound” economic theories. In 1937 a majority of the justices agreed with Taft’s dissent in West Coast Hotel Co. v. Parrish.