West Coast Hotel Co. v. Parrish

Elsie Parrish, a chambermaid working at the Cascadian Hotel in Wenatchee, Washington (owned by the West Coast Hotel Company), along with her husband, sued the hotel for the difference between what she was paid, and the $14.50 per week of 48 hours established as a minimum wage by the Industrial Welfare Committee and Supervisor of Women in Industry, pursuant to Washington state law. The trial court, using Adkins as precedent, ruled for the defendant. The Washington Supreme Court, taking the case on a direct appeal, reversed the trial court and found in favor of Parrish. The hotel appealed to the U.S. Supreme Court. ==Judgment==

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, where the Court had found in favor of the regulation of women's working hours. Hughes said the following: ==Significance==

The West Coast decision heralded the end of the Lochner era, when the US Supreme Court struck down numerous worker and consumer protection laws. During the Lochner era, the Supreme Court's conservative majority held that the Fourteenth Amendment guaranteed a "freedom of contract," which trumped efforts by legislators to protect workers or consumers. The doctrine continued to inform the Court's decisions through the Great Depression and the beginning of the New Deal, when it invalidated numerous worker and consumer protections. Just months prior to West Coast, a similar minimum wage law from New York was struck down in Morehead v. New York ex rel. Tipaldo. The majority in Morehead consisted of four conservative justices, sometimes called the "Four Horsemen", and a fifth Associate Justice, Owen Josephus Roberts. In response to the invalidation of so much legislation, President Franklin D. Roosevelt proposed to change the number of Supreme Court justices, which its opponents characterized as the "court-packing plan", his court reform bill was intended to dilute the influence of the older, anti-New Deal justices. Justice Roberts' vote to uphold the minimum wage law in West Coast Hotel, coming so soon after his vote to strike down a similar minimum wage law in Morehead, was unexpected and derailed Roosevelt's court reform bill. Many contemporary observers think Roberts' vote was a response to Roosevelt's court-packing plan, but Roberts denied it, and the evidence is mixed. Chief Justice Hughes stated in his autobiographical notes that Roosevelt's proposal to change the composition of the court "had not the slightest effect on our [the court's] decision" and that the delay in the ruling, which was caused only by Harlan Fiske Stone's absence, Hughes was able to persuade Roberts to stop basing his votes on his own political beliefs and to start siding with him during future decisions on New Deal legislation. In one of his notes from 1936, Hughes wrote that Roosevelt's re-election forced the court to depart from "its fortress in public opinion" and severely weakened its capability to base its rulings on personal or political beliefs. just two days after oral arguments concluded, and the Court was evenly divided only because pro-New Deal Associate Justice Stone was then absent for illness. In his dissenting opinion, Associate Justice Sutherland wrote that "the meaning of the Constitution does not change with the ebb and flow of economic events," a remark that has been read as an admonition aimed at Roberts. ==See also==