West Coast Hotel Co. v. Parrish

The Court concluded that Adkins was squarely implicated because the Washington law, like the District of Columbia law in Adkins, regulated the minimum wages of adult women. The case could not honestly be resolved through a distinction based on the hotel setting, because Adkins itself involved a woman employed by a hotel.

Reconsideration was proper even though Morehead v. New York ex rel. Tipaldo had recently followed Adkins. In Morehead, the petitioner had sought only to distinguish Adkins and had not asked the Court to reconsider its constitutional rule. Here, by contrast, the Washington Supreme Court had sustained the statute and rejected Adkins as controlling, directly presenting the validity of Adkins for reexamination.

The Court regarded fresh consideration as imperative because Adkins had been decided by a closely divided Court, many states had enacted similar protective laws, and severe economic conditions had highlighted the practical effects of inadequate wages. The Court found that Adkins departed from the established principles permitting reasonable state regulation of the employment relationship.

The Constitution protects liberty, not an absolute and unregulated “freedom of contract.” Liberty exists within a social order and remains subject to reasonable restraints adopted to protect the health, safety, morals, and welfare of the community. Due process is satisfied when regulation reasonably relates to a proper public purpose and is not arbitrary or discriminatory.

The Court’s precedents had long permitted substantial regulation of employment contracts, including limits on working hours, restrictions on unsafe work, wage-payment rules, and workers’ compensation systems. These cases recognized that employers and workers often do not bargain on equal terms and that the State may protect workers from oppression even when they are legally competent adults.

The distinction drawn in Adkins between maximum-hours laws and minimum-wage laws was unpersuasive. Both types of laws alter the terms of an employment bargain: hours and wages are equally central parts of the exchange. The Court accepted the earlier dissents’ view that regulation of either term is the same kind of interference with contractual liberty.

Washington’s law was reasonably designed to protect women against the effects of substandard wages. The wage-setting process considered particular occupations and included employers, employees, and public representatives; moreover, special licenses permitted lower wages for workers unable to perform full service. The statute did not compel an employer to hire anyone or require payment for services that did not support the business; it simply prohibited employment below a lawful minimum.

The legislature could find that women workers often had relatively weak bargaining power and were especially vulnerable to employers who exploited economic necessity. A living-wage requirement addressed the harmful “sweating system,” in which workers accepted wages too low to maintain health and basic well-being. Courts could not invalidate that legislative judgment merely because the policy’s wisdom or effects were debatable.

The Court also stressed the public consequences of substandard wages. When employers pay workers less than the cost of basic subsistence, the resulting shortfall may be borne by the public through relief and other community support. The State was therefore entitled to prevent the community from effectively subsidizing employers who paid unconscionably low wages.

A legislature need not regulate every instance of an evil at once. It may recognize degrees of harm and direct its restrictions where the need appears greatest, so long as its classification is not arbitrary. The fact that men might also suffer from low wages did not itself invalidate a law aimed at women workers.

The Court had repeatedly sustained protective labor laws that applied to women or to particular classes of women. In light of women’s relatively weak bargaining position and their susceptibility to the harms of exploitation addressed by the statute, Washington could reasonably treat their situation as demanding specific legislative protection.