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Adkins v. Children’s Hospital, 261 U.S. 525 (1923)

Case Name: Adkins v. Children’s Hospital
Citation: 261 U.S. 525 (1923)

 

Issue: Whether a District of Columbia act which instituted a minimum wage for women interfered with the freedom of contract under the 5th Amendment.

 

Facts: The act in question is a minimum wage law for women in the District of Columbia. It is argued that the act is unconstitutional because it interferes with the freedom of contract (included in the Due Process clause of the 5th Amendment). The other side is that it is within the police power of DC because it safeguards the morals of women.

 

Holding: The act “passes the limit prescribed by the Constitution.”

 

Reasoning: The differences between the sexes (as described in Muller v. Oregon) have diminished; especially, with the adoption of the 19th Amendment. A woman cannot be emancipated and given special protection in her contractual and civil relationships.

 

In response to the argument that the act is within the District of Columbia’s police power: “The relation between earnings and morals is not capable of standardization.” There are too many factors that determine the earnings a woman needs: individual temperament, habits of thrift, and whether a woman lives with a family or by herself. There is no reasonable connection between morals and wages.
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West Coast Hotel Co. v. Parrish, 300 U.S. 379 (1937)

Case Name: West Coast Hotel Co. v. Parrish
Citation: 300 U.S. 379 (1937)

 

Issue: Whether the Washington minimum wage law violates the Due Process Clause of the 14th Amendment.

 

Facts: Minimum wage law created by the state of Washington. Elsie Parrish was a chambermaid and sued to recover the difference between her wages and the state minimum wage ($14.50 per week of 48 hours). The hotel alleged that the minimum wage regulation is a deprivation of freedom of contract.

 

Holding: The minimum wage law was upheld and found to be within the state’s legislative power.

 

Reasoning: The Court believed that this subject should receive “fresh consideration” from previous decisions. The Constitution does not speak of “freedom of contract” but it does speak of “liberty and prohibits the deprivation of liberty without due process of law.”
The state is able to protect the public interest and “what can be closer to the public interest than the health of women and their protection from unscrupulous and overreaching employers?” The requirement of a minimum wage is an admissible means to the end of protecting women. The Court also discussed the “evils” of current employment conditions of women in sweatshops and how they have unequal bargaining power so freedom of contract is really a misnomer.

 

Another policy reason: The exploitation of workers also casts a direct burden upon the community for their support. Taxpayers are called to pay additional wages to the workers in order for them to meet the bare cost of living. Shouldn’t the manufacturer pay for these costs directly because they are receiving the benefit of selling goods in the marketplace?
The Court overruled Adkins stating that it “was a departure from the true application of the principles governing the regulation by the state of the relation of employer and employed.”