University:
Boston University
Course:
LAW AM 700 | Intro to American Law
Academic year:

2022
Views:

469

Pages:

2
Author:

gewoekerdodx

West Coast Hotel Co. v. Parrish 300 U.S. 379 (1937) Facts: Legally Relevant Facts : “Elsie Parrish, an employee of the West Coast Hotel Company, sued to recover wages owed her under the state law” (p.538). Procedurally Relevant Facts : “Overruled Adkins v. Children’s Hospital (1923) and, with it, the doctrine that courts can continually second-guess legislative judgments about the need for statues governing minimum wages, maximum hours and other aspects of industrial working conditions” (p.538). The Supreme Court of the Washington approved holding minimum wage, as it recognized the statue as a reasonable exercise. “The state court has refused to regard the decision in the Adkins case as determinative and has pointed to our decisions both before and since that case as justifying its position” (p.538). Issue(s): Is a statue of the state of Washington providing for the establishment of minimum wages for women violating liberty of contract? Holding: The case of Adkins v. Children’s Hospital is overruled and the judgement of the Supreme Court of the Washington is affirmed. Reasoning: “The Supreme Court of Washington has upheld the minimum wage statue of that State,” and that is a reasonable action. “In each case the violation alleged by those attacking minimum wage regulation for women is deprivation of freedom of contract,” but as Constitution does not specify freedom of contract; it only “speaks of liberty and prohibits the deprivation of liberty without due process of law” (p.538). However, “liberty in each of its phases has its history and connotation. But the liberty safeguarded is liberty in a social organization which requires the protection of law against the evils which menace the health, safety, morals and welfare of the people” (p.538). When considering the circumstances of the “women in employment, the fact that they are in the class receiving the least pay [makes] their bargaining power [to be] relatively weak, and they are the ready victims of those who would take advantage of their necessitous circumstances” (p.539). Therefore, they need protection from the State. Dissenting Opinions: Mr. Justice Sutherland Constitution should not be subject to change due to the flow of economic events. Also, “the suggestion that the only check upon the exercise of the judicial power, when properly invoked, to declare a constitutional right superior to an unconstitutional statue is the judge’s own faculty of self-restraint, is both ill-considered and mischievous” (p.539). As women hold same legal and political rights now, they should not be “put in different classes in respect of their legal right to make contracts” (p.539). Rather, they should be allowed to compete with men for work.