West Coast Hotel Co. v. Parrish

West Coast Hotel Co. v. Parrish
Supreme Court of the United States
Argued December 16–17, 1936 Decided March 29, 1937
Full case name	West Coast Hotel Company v. Elsie Parrish, et ux.
Citations	300 U.S. 379 (more) 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 history	Judgment for defendant, Chelan County Superior Court, November 9, 1935; reversed, 55 P.2d 1083 (Wash. 1936)
Subsequent history	None
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.
Court membership
Case opinions
Majority	Hughes, joined by Brandeis, Stone, Roberts, Cardozo
Dissent	Sutherland, joined by Van Devanter, McReynolds, Butler
Laws applied
U.S. Const. amend. XIV; Minimum Wages for Women Act, 1913 Wash. Laws 174
This case overturned a previous ruling or rulings
Adkins v. Children's Hospital (1923)

West Coast Hotel Co. v. Parrish, 300 U.S. 379 (1937), was a decision by the United States Supreme Court upholding the constitutionality of minimum wage legislation enacted by the State of Washington, overturning an earlier decision in Adkins v. Children's Hospital, 261 U.S. 525 (1923). The decision is usually regarded as having ended the Lochner era, a period in American legal history during which the Supreme Court tended to invalidate legislation aimed at regulating business.

Elsie Parrish, a chambermaid working 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 Washington state law. The trial court, using Adkins as precedent, ruled for the defendant. The Washington Supreme Court, taking the case on a direct appeal, reversed the trial court and found in favor of Parrish. The hotel appealed to the U.S. Supreme Court.

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. Hughes CJ said the following: