West Coast Hotel v. Parrish

1937

Venue: SCOTUS

Facts: Elsie Parrish works at a hotel, and wants to get minimum wage under state law. The employer thinks this interferes with liberty of contract.

Posture: Appeal by the hotel, which means probably Parrish won at trial.

Issue: Is the WA law "Minimum Wages for Women" constitutionally valid?

Holding: Yes. West Coast Hotel loses.

Rule: Sure, there's liberty of contract, but that's qualified, not absolute, and it's subject to reasonable regulation in the interests of the community.

Reasoning: Our previous decision in Adkins is overruled. The constitution doesn't stand for absolute uncontrolled liberty: liberty in a social organization requires protection (i.e., reasonable regulation) to guard against menaces to health, safety, morals, and welfare. Legislation for the protection of women can be sustained when the same law applied to men would be invalid, because "woman's physical structure and the performance of maternal functions places her at a disadvantage in the struggle for subsistence."

Dicta: Liberty is the absence of arbitrary restraint, not immunity from reasonable regulations.