What Is The West Coast Hotel V. Parrish Case

West Coast Hotel vs. Parrish

300 U.S. 379 (1937)

Facts

A case concerning substantive due process. Elsie Parrish, a chambermaid in a Washington State hotel, was discharged in 1935. She requested back pay for her labor in accordance with the 1913 Washington State Minimum Wages for Women Act, which, authorizes the fixing of minimum wages for women and minors. The Hotel refused to pay her all of her backpay, instead offering her a small portion of the amount. Parrish and her husband brought joint suit for backpay against the hotel. The Washington Supreme Court ruled in favor of Parrish and the Hotel appealed. The West Coast Hotel argued that the case should be decided in the same way as Adkins and Morehead. The Parrishes argued that the legislature

The decision of Adkins v. Children’s Hospital is overruled, and the judgment of the Supreme Court of Washington is affirmed.

Concurrences/Dissents

Justice Sutherland dissented: the question of this case should not have received fresh consideration because the “economic conditions have changed,” the meaning of the Constitution does not change with the ebb and flow of economic events. The only way to remedy a situation where the Constitution stands in the way of legislation is to amend the Constitution not to use the power of amendment under the guise of interpretation. Judges are constrained by the nature of their office and the Court must act as one unit.

Analysis

This case resulted in an explicit rejection of economic substantive due process. The Court overruled the holding in Adkins and changed the way the Court viewed state regulatory powers. The Court replaced substantive due process with a rational basis test that assumes the constitutionality of economic legislation and assigns responsibility to the law’s challengers to show there is not rational basis between the law and a legitimate government function. I disagree with the majority that the that this Washington state minimum wage requirement passes beyond the broad protective powers of the state. The decision in Adkins should have served as binding precedent and the Court should have held the law to be unconstitutional as well. I agree with Justice Sutherland that the meaning of the Constitution does not change with the ebb and flow of economic events and this law should not have been interpreted any differently than the one in Adkins because “economic conditions have