- West Coast Hotel Co. v. Parrish
__NOTOC__Infobox SCOTUS case
Litigants=West Coast Hotel Co. v. Parrish
FullName=West Coast Hotel Company v. Ernest Parrish, et ux.
Citation=57 S. Ct. 578; 81 L. Ed. 703; 1937 U.S. LEXIS 1119; 1 Lab. Cas. (CCH) P17,021; 8 Ohio Op. 89; 108 A.L.R. 1330; 1 L.R.R.M. 754; 7 L.R.R.M. 754
Prior=Judgment for defendant, Chelan County Superior Court, Nov. 9, 1935; reversed, 55 P.2d 1083 (Wash. 1936)
Holding=Washington's minimum wage law for women was a valid regulation of the right to contract freely because of the state's special interest in protecting their health and ability to support themselves. Supreme Court of Washington affirmed.
JoinMajority=Brandeis, Stone, Roberts, Cardozo
JoinDissent=Van Devanter, McReynolds, Butler
LawsApplied=U.S. Const. amend. XIV; Minimum Wages for Women Act, 1913 Wash. Laws 174
"West Coast Hotel Co. v. Parrish", 300 U.S. 379 (1937), was a decision by the
Supreme Court of the United Statesthat upheld the constitutionality of minimum wagelegislation enacted by the State of Washington, overturning an earlier decision in " Adkins v. Children's Hospital", 261 U.S. 525 (1923). Elsie Parrish, a chambermaidworking at the Cascadian Hotel in Wenatchee, Washington(owned by the West Coast Hotel Company), along with her husband, sued the hotel for the difference between what she was paid, and the $14.50 per week of 48 hours established as a minimum wage by the Industrial Welfare Committee and Supervisor of Women in Industry, pursuant to State law. The Washington State Supreme Court found in favor of Parrish, and the hotel appealed.
The Court, in an opinion by Chief Justice Hughes, ruled that the Constitution permitted the restriction of liberty of contract by state law where such restriction protected the community, health and safety or vulnerable groups, as in the case of "
Muller v. Oregon", 208 U.S. 412 (1908), where the Court had found in favor of the regulation of women's working hours.
"Muller", however, was one of the few exceptions of decades of Court invalidation of economic regulation, exemplified in "
Lochner v. New York", 198 U.S. 45 (1905). "West Coast Hotel" represents the end of that trend, and came about through a sudden and seemingly inexplicable shift in the voting habits of Justice Roberts. Coming as it did right when President Franklin D. Rooseveltwas pushing his "court packing" scheme to weaken the votes of the older anti- New Dealjustices, Roberts' move was notoriously referred to as " the switch in time that saved nine,". Roberts' conference vote was made on the same day as the court packing bill hit Congress and the opinion was issued seven weeks after Roosevelt's fireside chaton the subject.
Justice Sutherland's dissent contained a thinly veiled admonition to Roberts for switching sides, as well as an insistence that the Constitution does not change by events alone (namely, the
Great Depression). The dissent also adhered to the previously dominant perspective that the majority repudiated here: that freedom of contract was the rule with few exceptions, and that the shift of the burden for the poor onto employers was an arbitrary and naked exercise of power.
Although the majority's view on economic regulation remains the law of the land today, the expansion of
Commerce Clausejurisprudence signaled by "West Coast Hotel" was reined in slightly by " United States v. Lopez", 514 U.S. 549 (1995), and " United States v. Morrison", 529 U.S. 598 (2000).
List of United States Supreme Court Cases
Fair Labor Standards Act of 1938
case="West Coast Hotel Co. v. Parrish", 300 U.S. 379 (1937)
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