Supreme Court of the United States · 1937 · Constitutional Law
Constitutional Lawsubstantive due processminimum wageend of Lochner eraFourteenth Amendmentdue processpolice powerminimum wage
Facts
Washington enacted a law authorizing a state body to fix minimum wages for women and minors and declaring that inadequate wages and detrimental labor conditions harmed health and morals. After investigation and public hearings, the state fixed a minimum wage of $14.50 per week for 48 hours for women in the relevant occupation. Elsie Parrish worked as a chambermaid for West Coast Hotel and sued, with her husband, to recover the difference between what she was paid and the statutory minimum. The hotel argued that the law violated the Due Process Clause of the Fourteenth Amendment by infringing freedom of contract.
Issue
Does Washington's minimum wage law for women violate the Due Process Clause of the Fourteenth Amendment by unconstitutionally interfering with freedom of contract between employer and employee? More specifically, should Adkins v. Children's Hospital, which invalidated a similar minimum wage law, continue to control?
Rule
The liberty protected by the Due Process Clause includes no absolute freedom of contract. A state may regulate contractual relations, including employment, through its police power when the regulation is reasonable in relation to its subject, adopted in the interests of the community, and neither arbitrary nor discriminatory; every possible presumption favors the validity of such legislation.
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10 practice questions + 4 AI-graded essays on this case
One of 10 multiple-choice questions for this case. Pick an answer to see why.
Oregon enacts a statute requiring a labor board to set a minimum weekly wage for women employed in commercial laundries after investigation and public hearings. Cascade Linen House in Portland pays Nora Kim less than the board's order and argues the law violates the Fourteenth Amendment because it interferes with voluntary wage agreements between adults.
How should a court applying the majority's approach most likely rule?
Explanation. The majority held that liberty under the Due Process Clause does not include absolute freedom of contract. Economic regulation of employment is valid when it is reasonable in relation to its subject, adopted in the interests of the community, and not arbitrary or discriminatory. The Court specifically rejected the idea that minimum wage laws are unconstitutional merely because they regulate wage agreements between adults, and it also rejected any requirement that the business be specially affected with a public interest.