Adkins v. Children's Hospital 1923
Background: Washington D.C. had previously established a minimum wage for women and child workers in 1918. Along with the law came to board to supervise the distribution of wages in order to raise the standard of living for women and children to avoid conditions detrimental to their health and morals. The Children's Hospital of the District of Columbia sued to board, holding that its acts violated the liberty of contract as defined in Lochner v. New York in 1905.
Issue: Was the minimum wage law in violation of the liberty of contract and therefore unconstitutional.
Ruling/Impact: The Court ruled that a minimum wage law for women because it violated the Due Process Clause of the 5th amendment by denying women rights to freely contracted labor. The Court cited the Lochner case when it stated that it is the right of every citizen to obtain the most favorable terms they can through private negotiation. The law was considered especially arbitrary because it set a minimum wage for all women without taking into account their needs or level of skill. It also argued that because the law gave special protection to women it expressed their civil inferiority, but now that women's suffrage had been granted women could voice their concerns and demands in the political process and thus did not need the protections provided for by the law. Eventually, this ruling was overturned by West Coast Hotel v. Parrish (1937) which ruled states could impose a minimum wage on private businesses as long as the terms were reasonable enough they did not violate a citizen's right to life, liberty, or happiness.
Issue: Was the minimum wage law in violation of the liberty of contract and therefore unconstitutional.
Ruling/Impact: The Court ruled that a minimum wage law for women because it violated the Due Process Clause of the 5th amendment by denying women rights to freely contracted labor. The Court cited the Lochner case when it stated that it is the right of every citizen to obtain the most favorable terms they can through private negotiation. The law was considered especially arbitrary because it set a minimum wage for all women without taking into account their needs or level of skill. It also argued that because the law gave special protection to women it expressed their civil inferiority, but now that women's suffrage had been granted women could voice their concerns and demands in the political process and thus did not need the protections provided for by the law. Eventually, this ruling was overturned by West Coast Hotel v. Parrish (1937) which ruled states could impose a minimum wage on private businesses as long as the terms were reasonable enough they did not violate a citizen's right to life, liberty, or happiness.