Judgments

West Coast Hotel Vs Parris: State Can Fix Minimum Wage

West Coast Hotel Vs Parris (1937 ) ended the Lochner Era which is known for invalidation of legislations for economic regulation.  The Supreme Court upheld the validity of minimum wage legislation passed by Washington State.

What were facts of West Coast Hotel Vs Parris ?

Elsie Parris was a maid who worked at Cascadian Hotel in Wenatchee, Washington owned by West Coast Hotel. She sued the Hotel as she was not being paid minimum wages fixed in pursuance of Washington State Laws. The trial court dismissed the suit of the Elsie Parrish. On appeal the Washington Supreme Court reversed the finding of the trial court and ruled in favor of Elsie Parrish. The Hotel appealed before the Federal Supreme Court.

What were findings of the Supreme Court in West Coast Hotel Vs Parris ?

The Court held that the Constitution permitted restrictions on the grounds of health and safety of workers.

The principle which must control our decision is not in doubt. The constitutional provision invoked is the due process clause of the Fourteenth Amendment governing the states, as the due process clause invoked in the Adkins Case governed Congress. In each case the violation alleged by those attacking minimum wage regulation for women is deprivation of contract. What is this freedom ? The Constitution does not speak of freedom of contract. It speaks of liberty and prohibits the deprivation of liberty without due process of law. In prohibiting that deprivation, the Constitution does not recognize an absolute and uncontrollable liberty. Liberty in each of its phases has its history and connotation. But the liberty safeguarded is liberty in a social organization which requires the protection of law against the evils which menace the health, safety, morals and welfare of the people. Liberty under the Constitution is thus necessarily subject to the restraints of due process and regulation which is reasonable in relation to its subject and is adopted in the interests of the community.

West Coast Hotel Vs Parris

The Supreme Court held that power under the Constitution to restrict freedom of contract has had many illustrations which can  be exercised in the public interest with respect to contracts between employer and employee. During so called Lochner Era many workers laws and consumer laws were being invalidated by the Supreme Court causing frustration to the Executive. President Franklin D. Roosevelt had even started plan to change the number of judges of the Supreme Court, which is known as “Court Packing Plan”. With this judgment a change in approach of the Supreme Court can be discerned.

____________________________________

Mukesh Kumar Suman is an advocate and legal author based at Delhi. He regularly appears before various Judicial Forums including NCLT, NCLAT, High Courts and the Supreme Court. He can be approached at mukesh_suman@outlook.com or +91 9717864570.

Mukesh Kumar Suman

Mukesh Kumar Suman

Mukesh Kumar Suman is an advocate based at Delhi. He has rich experience in civil, criminal, commercial, arbitration and corporate insolvency matters. He regularly appears before District Courts, NCLT, NCLAT, High Court and the Supreme Court. He can be approached at mukesh_suman@outlook.com or +91 9717864570.

Leave a Reply

Your email address will not be published. Required fields are marked *