West Coast Hotel Co. v. Parrish
In the case of West Coast Hotel Co. v. Parrish, 300 U.S. 379 (decided March 29, 1937), the Supreme Court of the United States upheld the constitutionality of minimum wage legislation enacted by the State of Washington, overturning an earlier opinion in the case of Adkins v. Children's Hospital (261 U.S. 525, 1923).
The Court, in an opinion by Chief Justice Hughes, ruled that the Constitution permitted the restriction of liberty of contract by state law where such restriction protected the community, health and safety or vulnerable groups, as in the case of Muller v. Oregon (208 U.S. 412, 1908) where the Court had found in favour of the regulation of women's working hours.
Muller, however, was one of the few exceptions of decades of Court invalidation of economic regulation, exemplified in Lochner v. New York. West Coast Hotel represents the end of that trend, and came about through a sudden and seemingly inexplicable shift in the voting habits of Justice Roberts. Coming as it did right when President Roosevelt was pushing his "court packing" scheme to weaken the votes of the older anti-New Deal justices, Roberts' move was notoriously referred to as "the switch in time that saved nine."
Justice Sutherland's dissent contained a thinly veiled admonition to Roberts for switching sides, as well as an insistence that the Constitution does not change by events alone (namely, the Great Depression). The dissent also adhered to the previously dominant perspective that the majority repudiated here: that freedom of contract was the rule with few exceptions, and that the shift of the burden for the poor onto employers was an arbitrary and naked exercise of power. However, the majority's view on economic regulation continued to hold sway over the Court in the decades to come.
See also:
Referenced By
A.L.A. Schechter Poultry Corp. v. United States | Adkins v. Children's Hospital | Franklin D. Roosevelt | Franklin Delano Roosevelt | Franklin Deleno Roosevelt | Franklin Roosevelt | List of United States Supreme Court Cases | Lochner v. New York | Muller v. Oregon | Schechter Poultry Corp. v. United States | Schechter v. United States | Schecter v. U.S.
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