West Coast Hotel Co. v. Parrish

Majority reasoning

The majority, led by Chief Justice Hughes, held that liberty under the Constitution is not absolute freedom of contract but liberty subject to reasonable regulation protecting the community's health, safety, and welfare. The Court reasoned that women workers have historically had weaker bargaining power and are vulnerable to exploitation by employers who could pay below-subsistence wages, and that the state has a legitimate interest in preventing this "sweating system" of exploitation. The majority emphasized that when employers pay wages insufficient for subsistence, taxpayers effectively subsidize those employers by covering workers' unmet needs through relief programs, giving the state added reason to regulate. The Court found no meaningful constitutional distinction between regulating maximum hours (already upheld in prior cases) and regulating minimum wages, rejecting the argument that wage-fixing was categorically different from hour-fixing. It concluded that Adkins v. Children's Hospital represented a departure from established principles governing state regulation of employment relationships and should be overruled.

Dissent reasoning

Justice Sutherland (writing for the dissenting justices in the incorporated Adkins-style reasoning within the opinion, representing the view that the Washington statute was invalid) argued that the statute was, in every substantial respect, identical to the District of Columbia law struck down in Adkins, and that if Adkins was correctly decided, the Washington law must likewise be unconstitutional. The dissenting reasoning held that minimum wage laws for women alone constitute arbitrary discrimination, since adult women possess the same legal capacity to contract as men, and no legitimate basis exists for restricting only women's contractual freedom while leaving men free to negotiate wages. It further argued that the law considers only the employee's needs while ignoring the employer's capacity to pay, effectively forcing employers to subsidize a class of workers regardless of the value of services rendered, and that this burden, if it belongs to anyone, belongs to society as a whole rather than being arbitrarily shifted onto individual employers.