West Coast Hotel Co. v. Parrish
West Coast Hotel Co. v. Parrish is a significant U.S. Supreme Court case from 1937 that addressed the issue of minimum wage laws and workers' rights. The case arose when Elsie Parrish, an employee at the West Coast Hotel in Washington, sued the company for unpaid wages, as her compensation of twenty-five cents an hour fell below the state's minimum wage of $14.50 per week. This ruling was made by the Washington State Supreme Court, despite the recent Supreme Court decision in Morehead v. New York, which had struck down minimum wage laws for women.
Upon appeal, the U.S. Supreme Court upheld the Washington court's decision in a closely contested 5-4 vote, marking a pivotal moment in labor rights legislation. Chief Justice Charles Evans Hughes argued that the due process clause did not prevent state intervention to regulate wages for the welfare of workers. This ruling signified a shift in the Court's approach, emphasizing greater respect for state regulations relating to workers' rights and establishing a more favorable environment for labor protections. Ultimately, West Coast Hotel Co. v. Parrish played a crucial role in what is often referred to as the constitutional revolution of 1937, influencing the future of labor laws and the balance of governmental powers in economic regulation.
West Coast Hotel Co. v. Parrish
Date: March 29, 1937
Citation: 300 U.S. 379
Issue: Freedom of contract
Significance: Abandoning its long-standing freedom of contract doctrine, the Supreme Court allowed states great discretion in regulating working conditions and protecting the rights of employees.
In 1935 Elsie Parrish, a resident of the state of Washington, was discharged from her job with the West Coast Hotel Company. She was being paid twenty-five cents an hour, which was significantly less than the state’s minimum wage of $14.50 per week, set by a commission according to a 1913 law. Parrish sued the company for $216.19, which was the difference between the minimum wage and her actual wages during her employment. Although the Supreme Court had overturned a minimum-wage law for women as recently as Morehead v. New York ex rel. Tipaldo (1936), the Washington State supreme court ruled in favor of Parrish’s claim. The hotel company appealed the judgment to the Supreme Court.
Less than two months after President Franklin D. Roosevelt announced his court-packing plan, the Court formally upheld the Washington court’s ruling with a 5-4 vote. Justice Owen J. Roberts, who had voted to strike down a minimum-wage law in Morehead, joined the West Coast Hotel majority the famous “switch in time that saved nine.” Writing for the majority, Chief Justice Charles Evans Hughes argued that the liberty of the due process clause did not prohibit state government from using their police powers to establish reasonable regulations in the interests of the community. He found that it was entirely reasonable to restrict the freedom of contract in order to provide women with a living wage, a policy clearly related to the promotion of health and welfare. He also noted that an earlier Court had approved of maximum-hour legislation for women, and he could find no relevant difference between the regulation of hours and the regulation of wages.
West Coast Hotel was one of the major decisions of the so-called constitutional revolution of 1937. In effect, the landmark decision meant that the Court would henceforth give greater deference to the judgment of legislatures, and that it would no longer strike down labor regulations based on a substantive due process reading of the Fourteenth Amendment.