## Facts

- Congress enacted the District of Columbia Minimum Wage Law of 1918, authorizing a wage board to set minimum wages for women and minors sufficient for living costs and worker health and welfare.
- The Children’s Hospital of the District of Columbia, an employer of women, and Willie Lyons, a 21-year-old female elevator operator, sought to prevent enforcement of the statute.
- They alleged the law forced employers to pay a board-set minimum wage regardless of private bargaining, affecting employment relationships.
- The trial court dismissed the suits and upheld the statute.
- The Court of Appeals of the District of Columbia initially affirmed, then granted rehearings during the same term, reversed, and ordered injunctions against enforcement; on subsequent appeals it affirmed the injunction decrees.
- Members of the D.C. Minimum Wage Board, including Jesse C. Adkins, sought Supreme Court review.

## Issues

1. Whether the Court of Appeals of the District of Columbia lacked power to grant rehearings and reverse its earlier affirmance at the same term in a manner that affected review of the final injunction decrees.
2. Whether the District of Columbia minimum wage law for women and minors violates the Fifth Amendment Due Process Clause by interfering with liberty of contract in employment.

## Decision

- The Supreme Court affirmed the Court of Appeals’ final decrees enjoining enforcement of the statute.
- Procedurally, objections to the Court of Appeals’ rehearings practice did not defeat review of the final decrees before the Supreme Court.
- On the merits, the Court held the minimum wage law unconstitutional under the Fifth Amendment because it imposed an impermissible restraint on freedom of contract between employer and employee.
- The Court distinguished maximum-hours regulations from minimum-wage requirements, reasoning that wage floors directly control the price term of labor and bar agreements for lower wages even if voluntary.
- The Court rejected a categorical justification for singling out adult women for wage protection, reasoning that legal and political developments (including the Nineteenth Amendment) weakened prior rationales for restricting women’s contracting freedom differently from men’s.

## Legal Principles

- Liberty protected by the Fifth Amendment Due Process Clause includes the right of competent adults to make employment contracts, subject only to limited exceptions.
- Economic regulation that fixes minimum wages for private employment is a direct and substantial interference with wage bargaining and requires a compelling justification within recognized police-power limits.
- Maximum-hours laws and minimum-wage laws are not constitutionally equivalent: limiting hours may leave wage bargaining intact, while wage floors dictate a core contract term.
- A “living wage” scheme that compels payment based on workers’ needs rather than the value of the work was treated as exceeding permissible regulation of health, safety, and welfare in private employment relations.

## Conclusion

The Court invalidated the District of Columbia’s minimum wage statute for women and minors, holding that it violated the Fifth Amendment by unconstitutionally restricting freedom of contract in employment and by setting wages through a board-imposed floor rather than private bargaining.


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