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Analysis of Constitutional Interpretation of the Due Process Clause of the Fourteenth Amendment

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Ultimately, the SCOTUS held in this case that the minimum wage law was constitutional because it sensibly controlled contracts to protect both the health and well being of the workers.

Justices Hughes, McReynolds, Stone, Brandeis, and Cardozo held the majority opinion. These SCOTUS justices arrived at this decision with agreement as delivered by Justice Hughes by the main reasoning that the freedom of contract is not directly mentioned in the Constitution. However, the Constitution does directly specify the right of liberty and outlaws stripping liberty when there is no procedural due process. According to the majority, liberty is conditional upon suppressing the due process as well as rational regulation by the state to protect its best interests (Skelton). The majority additionally reasoned that under the Due Process Clause, Washington’s statute did not breach the freedom of contract because it was reasonable besides being in the best economic and social interests of the state. In addition, the majority reasoned that the government has a full discretionary field when it comes to matters about protecting the health and wellbeing of U.S. citizens (Bernstein). Therefore, exploiting low class workers who have different and less bargaining power with other people is harmful to their welfare. Besides approaching the matter from a chronological of events perspective, historians have occasionally debated on whether the political and ideological atmosphere at the time affected the unexpected turn of events demonstrated by Justice Roberts in this case (Skelton). Roberts could have been influenced by President Roosevelt’s presidential reelection or the positive accomplishments of the New Deal causing him to shift his party affiliation away from conservatism. Major criticisms arouse from Justice Sutherland, who stated that politics as well as public opinion should not have an influence on the court’s judicial interpretation of the Constitution. (“West Coast Hotel v. Parrish”)

The majority opinion led the court to the conclusion to overturn the Adkins v. Children’s Hospital decision in 1923 (White). At the time, West Coast Hotel v. Parrish was a highly controversial case, although it has become sensible in today’s world. The decision reached by the SCOTUS immediately repudiated the landmark decision reached in Adkins v. Children’s Hospital case. This particular case ruled that laws regarding fixed employment terms in contracts automatically breached the Clause of Due Process, which preserves a citizen’s substantive freedom to contract labor freely. Political and economic pressures lead the court to dismiss the substantive due process as inadequate. The decision in West Coast Hotel v. Parrish case was made immediately after President Roosevelt recommended a “court-packing scheme” that would, in turn, add some justices issued in “anti-Lochner” to the court as a way of protecting the New Deal ratification along with progressive laws to help economic development (Skelton). However, in the Adkins v. Children’s Hospital case, SCOTUS voted before Roosevelt publicly announced his plan. In this case, the court ruled that federal minimum wage laws that were applied to women were unconstitutional deprivations of liberty of contract. Yet, with the help of Roosevelt’s court-packing strategy, SCOTUS decision in the West Coast Hotel v. Parrish case affirmed the State of Washington’s Supreme Court’s initial judgment, by declaring that Washington’s minimum wage statute is constitutional and not an infringement of liberty due to the fact that its goal is to serve as protection for the prosperity of the state and health, happiness, and fortunes for its citizens.

Justice Hughes asserted that considering the fact that it was 1913 when Washington’s first bill dealing with minimum wage was introduced as it was passed by a sweeping majority of both Houses of Congress and fully established in 1923, known as the Piper Bill, in efforts to ensure safety over women’s health and morality that the court’s majority opinion is constitutionally justified. Not only taking into account the year of 1913 when it was first introduced but also having awareness of the irregular patterns of economic and social events occurring between 1913 and 1923 legally supports Washington statute’s grant of police power over minimum age is constitutional (White). In equivalence, the majority opinion took into consideration the economic crisis and financial burdens people and the state were facing at the time as the procedural Due Process Clause and the Fourteenth Amendment of the Constitution were respectively obeyed, as Washington’s passed its statute appropriately through the state’s legislative process for the purpose of upholding the constitutionality of it government’s duties to protect and maintain security of its state along with its citizens.

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Justice George Sutherland was at first the only holder of a dissent opinion, but later on Justices Van Devanter, McReynolds, and Butler joined in to support his divergent argument These Justices argued that the appellate court’s decision should be reviewed and overruled. They reasoned that changes in political or economic events must not alter the court’s understanding of the Constitution. (“West Coast Hotel v. Parrish”) They further argued that the Constitution is not a document that can be interpreted in current circumstances. Justice Sutherland claims, “the words of the Constitution mean today what they did not mean when written-that is, that they do not apply to a situation now to which they would have applied then” (Bernstein). Therefore, the only way the court can interpret the Constitution in context to the current time they are in and change it is by issuing a constitutional amendment to ensure that it is not subject to modification by the actions and feelings of the public. Justice Sutherland believed that the judicial interpretations of the Constitution concrete and unchangeable to the ever changing economic, political, or social events of the world (White). The dissenting opinion reasoned that the court is not in a position to determine the constitutionality of legislation that has already been endorsed by the government’s executive branches in terms of social and economic matters. By doing so, the court would be degrading the separation of powers.

Additionally, the dissenters reasoned that freedom of contract is a rule as well as a prohibition that can only be substantiated by exceptional occurrences or circumstances (“West Coast Hotel Company v. Parrish”). Finally, the justices that fell outside the majority held that a state could not have interest in fixing wages for only women and minors because by doing so illustrates that there is gender and age discrimination. They believed that both genders are equally capable of contracting out their labor and should have that liberty and that different age generation shouldn’t be deprived of opportunities based on their age while everyone should have equal liberty to contract.

The majority vote was the more superior opinion because the state had a valid reason to have vested interest in the wages paid to women and children because if the salary for women or minors dropped below a certain level, public support of the state government would fall to a certain degree and the government could be accused of not fulfilling its required duties for the people. In addition, women and children hold unequal bargaining power when compared to their employers throughout the contract process in the business world. Consequently, the state’s interest to enforce a law to improve workplace equality and maintain human welfare standards is fair and constitutionally acceptable. The majority and dissenting opinions represented the major struggle in this case about how the court should interpret the constitution on the basis of either reasserting strongly the initial foundations of the Constitution or affirming a judicial awareness of continuously changing social and economic circumstances of the states.

The decision made in this case plays a significant role in developing the meaning of the U.S. constitutionalism in that it has helped the government understand the Constitution and governmental branches are legally restricted in their individual powers, which makes its legitimacy rely on these constraints. Justice Hughes’ majority opinion exercises “living constitutionalism” in contrast to Justice Sutherland’s dissenting opinion, which addresses original intent of the authors of the Constitution (Bernstein). The Constitution needs to adapt to change throughout time since everything else changes and thus, Hughes’ opinion is more acceptable providing support that judicial decisions should be made on the basis of an adaptable and working Constitution.

All embracing, in this case, the Washington State’s minimum-wage law for women and minors constitutionality was upheld by the SCOTUS, overturning Adkins v. Children’s Hospital, thus upholding the constitutionality of the National Labor Relations Act of 1935 and the Social Security Act of 1935. However, it is paramount to note that although political and economic pressures may affect a court’s ruling, they should not impact its constitutional knowledge. The contemporary effects that this case’s decision had to include combating any harmful impact on employees’ health and wellbeing as well as protecting minority groups like women and children from hazardous working conditions. These effects are long term because even today, there is tons of legislation built from this case protecting men, women, and children against mistreatment and abuse among other things in more areas besides the work place. The West Coast Hotel v. Parrish case can be noteworthy, not simply as a triumph of judicial activism but also because the Court purposefully restored the original constitutional interpretation of the Due Process Clause of the Fourteenth Amendment, which had been distorted by advocates of the liberty of contract doctrine.

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Analysis of Constitutional Interpretation of the Due Process Clause of the Fourteenth Amendment. (2022, August 12). Edubirdie. Retrieved December 1, 2022, from
“Analysis of Constitutional Interpretation of the Due Process Clause of the Fourteenth Amendment.” Edubirdie, 12 Aug. 2022,
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Analysis of Constitutional Interpretation of the Due Process Clause of the Fourteenth Amendment [Internet]. Edubirdie. 2022 Aug 12 [cited 2022 Dec 1]. Available from:
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