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West Coast Hotel Co. v. Parrish

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Significance: Abandoning its long-standing freedom of contract doctrine, the Supreme Court allowed states great discretion in regulating working conditions and protecting the rights of employees.


In 1935 Elsie Parrish, a resident of the state of Washington, was discharged from her job with the West Coast Hotel Company. She was being paid twenty-five cents an hour, which was significantly less than the state's minimum wage of $14.50 per week, set by a commission according to a 1913 law. Parrish sued the company for $216.19, which was the difference between the minimum wage and her actual wages during her employment. Although the Supreme Court had overturned a minimum-wage law for women as recently as Morehead v. New York ex rel. Tipaldo (1936), the Washington State supreme court ruled in favor of Parrish's claim. The hotel company appealed the judgment to the Supreme Court. Less than two months after President Franklin D. Roosevelt announced his court-packing plan, the Court formally upheld the Washington court's ruling with a 5-4 vote. Justice Owen J. Roberts, who had voted to strike down a minimum-wage law in Morehead, joined the West Coast Hotel majority the famous “switch in time that saved nine.” Writing for the majority, Chief Justice Charles Evans Hughes argued that the liberty of the due process clause did not prohibit state government from using their police powers to establish reasonable regulations in the interests of the community. He found that it was entirely reasonable to restrict the freedom of contract in order to provide women with a living wage, a policy clearly related to the promotion of health and welfare. He also noted that an earlier Court had approved of maximum-hour legislation for women, and he could find no relevant difference between the regulation of hours and the regulation of wages. West Coast Hotel was one of the major decisions of the so-called constitutional revolution of 1937. In effect, the landmark decision meant that the Court would henceforth give greater deference to the judgment of legislatures, and that it would no longer strike down labor regulations based on a substantive due process reading of the Fourteenth Amendment.