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    West Coast Hotel Co. v. Parrish (Short Brief)

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    Daniel N. Clay
    This case involves a minimum wage law passed by Washington state. An employee, Elsie Parrish, was paid below the minimum wage and sued to recover the difference. The lower courts found the law unconstitutional but the state Supreme Court disagreed. The US Supreme Court then heard the case. In a 5-4 decision, the Court upheld the minimum wage law, overturning a prior decision. The Court found that while the 5th and 14th Amendments protect liberty, reasonable regulations adopted to protect the community do not violate due process. Minimum wage laws regulate contracts in a way that protects vulnerable workers.

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    West Coast Hotel Co. v. Parrish (Short Brief)

    Uploaded by

    Daniel N. Clay
    1K views2 pages
    This case involves a minimum wage law passed by Washington state. An employee, Elsie Parrish, was paid below the minimum wage and sued to recover the difference. The lower courts found the law unconstitutional but the state Supreme Court disagreed. The US Supreme Court then heard the case. In a 5-4 decision, the Court upheld the minimum wage law, overturning a prior decision. The Court found that while the 5th and 14th Amendments protect liberty, reasonable regulations adopted to protect the community do not violate due process. Minimum wage laws regulate contracts in a way that protects vulnerable workers.

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    This case involves a minimum wage law passed by Washington state. An employee, Elsie Parrish, was paid below the minimum wage and sued to recover the difference. The lower courts found the law unconstitutional but the state Supreme Court disagreed. The US Supreme Court then heard the case. In a 5-4 decision, the Court upheld the minimum wage law, overturning a prior decision. The Court found that while the 5th and 14th Amendments protect liberty, reasonable regulations adopted to protect the community do not violate due process. Minimum wage laws regulate contracts in a way that protects vulnerable workers.

    Copyright:

    Attribution Non-Commercial (BY-NC)
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    1K views2 pages

    West Coast Hotel Co. v. Parrish (Short Brief)

    Uploaded by

    Daniel N. Clay
    This case involves a minimum wage law passed by Washington state. An employee, Elsie Parrish, was paid below the minimum wage and sued to recover the difference. The lower courts found the law unconstitutional but the state Supreme Court disagreed. The US Supreme Court then heard the case. In a 5-4 decision, the Court upheld the minimum wage law, overturning a prior decision. The Court found that while the 5th and 14th Amendments protect liberty, reasonable regulations adopted to protect the community do not violate due process. Minimum wage laws regulate contracts in a way that protects vulnerable workers.

    Copyright:

    Attribution Non-Commercial (BY-NC)
    Download as DOCX, PDF, TXT or read online from Scribd
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    Daniel N.

    Clay

    West Coast Hotel Co. v. Parrish


    300 U.S. 379 (1937)

    FACTS: In 1913, the state of Washington enacted a minimum to protect women and minorities.
    The Respondent (Elsie Parrish), an employee of the Petitioner (West Coast Hotel Co.), was paid
    a sub-minimum wage and filed suit to recover the balance between her wage and the minimum
    wage set by state statute. The lower state courts ruled the statute unconstitutional, but the
    Washington State Supreme Court overturned this decision and ruled in favor of Parrish. The
    Petitioner appealed this decision to the United States Supreme Court on the basis that a state set
    minimum wage violates the "liberty of contract” constructed by the Fifth Amendment of the U.S.
    Constitution as applied by the Fourteenth Amendment.

    ISSUES:
    A. Does the minimum wage law violate the “liberty of contract” construed under the Fifth
    Amendment as applied by the Fourteenth Amendment?

    HOLDING: A. No

    REASONING: Per HUGHES: This case calls for a re-examination of the precedent established
    by Adkins v. Children’s Hospital (1923) which overturned Washington D.C.’s minimum wage
    under the Fifth Amendment due to the change in economic conditions (the Great Depression).
    Both cases involve the “freedom of contract,” however the 5th and 14th Amendment does not
    mention contracts, it only speaks of liberty and places a limit on liberty by due process of law.
    As such, regulation which is reasonable in relation to its subject and is adopted in the interests of
    the community is due process. This limitation of liberty in particular governs the “freedom of
    contract.” There is no absolute freedom to do as one wills or to contract as one chooses, because
    liberty implies the absence of arbitrary restraint, not immunity from reasonable regulation
    imposed in the interests of the community. This allows for state intervention when the state holds
    a particular interest of protection; especially when the parties to a contact “do not stand on
    equality,” such as in an employer/employee relationship.

    DISSENTING OPINION: Per SUTHERLAND: Economic conditions should not be grounds for
    the re-examination of the precedent established by Adkins v. Children’s Hospital (1923) because
    to say that the Constitution changes with the times and has to potential to not mean something
    now that it meant with the document was drafted does it a disservice. Considerations of what the
    statute will ultimately do, good or bad, should not be considered by the Court, it must only
    answer the constitutional considerations involved. As such, while legislatures are free to
    recognize degrees of harm, the statute only applies to women and since the contractual rights of
    men and women are the same the statute creates an arbitrary discrimination based on sex. This
    implies that the bargaining abilities of women and men are not equal because of gender which is
    inherently untrue.

    Justices BUTLER, MCREYNOLDS, and VAN DEVANTER also dissented.

    SUMMARY OF LEGAL PRINCIPLES: This case involves the legal principle of “freedom on
    contract” as established by the Fifth Amendment. However the 5th and 14th Amendments do not
    Daniel N. Clay

    reference contracts but instead state that liberty cannot be deprived without due process of law.
    While due process of law is yet another abstract term the court defined it in reference to
    contracts: “regulation which is reasonable to its subject and is adopted in the interests of the
    community is due process.” In other words, legislatures can place limits on liberty, specifically
    “freedom of contract,” as long as the regulation is not arbitrary and reasonable to the extent that
    is protects the interests of the community as a whole. Since legislatures are free to recognize
    degrees of harm, regulations can be made to address the varying degrees, such as a minimum
    wage for women.

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