Facts
- Washington enacted a 1913 “Minimum Wages for Women” law authorizing an Industrial Welfare Commission to set minimum wages and labor conditions for women and minors.
- The Commission set a minimum wage of $14.50 for a 48-hour work week for women.
- Elsie Parrish worked as a chambermaid for West Coast Hotel Company’s Cascadian Hotel and was paid less than the minimum wage.
- Parrish (with her husband) sued to recover the difference between her pay and the statutory minimum.
- The trial court entered judgment for the hotel, relying on precedent invalidating a similar minimum-wage law for women.
- The Washington Supreme Court reversed and ordered a money judgment for Parrish.
- The hotel sought review in the U.S. Supreme Court.
Issues
- Whether Washington’s minimum-wage law for women violated the Fourteenth Amendment Due Process Clause by infringing “liberty of contract.”
- Whether setting minimum wages for women is a permissible exercise of the state’s police power when justified as protecting health, safety, morals, and general welfare.
- Whether the Court should follow prior precedent invalidating women’s minimum-wage legislation.
Decision
- The Supreme Court affirmed the Washington Supreme Court in a 5–4 decision.
- The Court held that Washington’s minimum-wage law for women was constitutional under the Fourteenth Amendment.
- The Court expressly overruled Adkins v. Children’s Hospital and distinguished Morehead v. New York ex rel. Tipaldo.
- The Court rejected the claim that the statute was unconstitutional discrimination because it applied to women (and minors) but not men.
Legal Principles
- The Due Process Clause protects “liberty,” but it does not confer an absolute freedom of contract; liberty is subject to reasonable regulation to protect the public welfare.
- Economic and labor regulation satisfies due process when it is reasonable in relation to its subject and adopted in the interests of the community.
- In regulating employer–employee relations, legislatures have broad discretion to address exploitation and working conditions that affect health, safety, morals, and welfare.
- A state may treat women as a class warranting special protection in employment where the legislature finds that substandard wages and conditions threaten women’s health and impose social costs on the community.
- The Constitution permits minimum-wage laws aimed at preventing wages so low that they shift the cost of worker maintenance to taxpayers.
Conclusion
The Court sustained state authority to set minimum wages for women as a valid exercise of police power consistent with Fourteenth Amendment due process, rejected an absolutist liberty-of-contract approach, and overruled Adkins, signaling a decisive shift toward judicial deference to economic regulation.