West Coast Hotel Company v. Parrish Case Brief

Facts of the case

Under Washington state law, the Industrial Welfare Committee and Supervisor of Women in Industry set a minimum wage of $14.50 for each work week of 48 hours. Elsie Parrish, an employee of the West Coast Hotel Company, received an amount less than this wage. Parrish brought a suit to recover the difference between the wages paid to her and the minimum wage fixed by state law. In ruling for the hotel, the lower court relied on Adkins v. Children’s Hospital (1923) , in which the Court struck down a minimum wage law for working women.

Why is the case important?

Washington instituted a state wage minimum for women and minors. The Appellant, West Coast Hotel (Appellant), paid the Appellee, Parrish (Appellee), less than this minimum.

Question

Is the fixing of minimum wages for women and minors constitutional?

ANSWER

Yes. This case overrules Adkins v. Children’s Hospital.
The exploitation of a class of workers who are at a disadvantaged bargaining position is not in the best interest of the health of the worker and economic health of the community.

CONCLUSION

It was a valid exercise of the state’s police power to protect the health and safety of women. The Court reasoned that the state had a valid interest in the wages paid to women because their support would fall on the state if women were not paid adequate wages. The Court specifically overruled a case relied on by the employer which held that minimum wages laws for women were an unconstitutional burden on the right to contract. The Court reasoned that the case could not stand because employers and employees did not stand on equal footing in the contract process, and the state’s interest in the protection of women was valid. The Court held that equal protection was not violated because there was no doctrinal requirement that required the legislation to be couched in all-embracing terms. The Act was directed at a social position unique to women, so the Act did not constitute arbitrary discrimination.

  • Advocates: E. L. Skeel for the appellant W. A. Toner for the appellees
  • Appellant: West Coast Hotel Company
  • Appellee: Ernest Parrish and Elsie Parrish, his wife
  • DECIDED BY:Hughes Court
  • Location: The Cascadian Hotel
Citation: 300 US 379 (1937)
Argued: Dec 16 – 17, 1936
Decided: Mar 29, 1937
West Coast Hotel Company v. Parrish Case Brief