Adkins et al. v. Children's Hospital of the District of Columbia
261 U.S. 525 (1923)
Rule of Law:
A statute authorizing the fixing of minimum wages for adult women, based on the cost of living rather than the value of the services rendered, is an unconstitutional interference with the liberty of contract protected by the Due Process Clause of the Fifth Amendment.
Facts:
- The District of Columbia enacted a law creating a board to set minimum wages for women and minors to protect their health and morals.
- Children's Hospital employed a number of women with whom it had mutually satisfactory wage agreements.
- Some of these agreed-upon wages were less than the minimum wage subsequently fixed by the board under the new law.
- Willie A. Lyons, a 21-year-old woman, worked as an elevator operator for the Congress Hall Hotel Company.
- Lyons and the Hotel Company were both satisfied with her wages of $35 per month plus two meals a day, which was less than the board's mandated minimum.
- Due to the board's order and the act's penalties, the Hotel Company was compelled to discharge Lyons.
- Lyons alleged that she was unable to obtain other employment with wages and conditions as good as the job she lost.
Procedural Posture:
- Children's Hospital and Willie Lyons filed separate suits against the Minimum Wage Board (headed by Jesse Adkins) in the Supreme Court of the District of Columbia, a trial court.
- The plaintiffs sought to enjoin the enforcement of the minimum wage order.
- The trial court denied the injunctions and dismissed the cases.
- The plaintiffs (appellants) appealed to the Court of Appeals of the District of Columbia.
- The Court of Appeals first affirmed the trial court's decision.
- Subsequently, the Court of Appeals granted a rehearing, reversed its own prior opinion, and held the act unconstitutional, remanding the cases to the trial court.
- The trial court then entered permanent injunctions against the Minimum Wage Board.
- The Minimum Wage Board (appellant) appealed these injunctions back to the Court of Appeals, which affirmed the trial court's decrees.
- The Minimum Wage Board then appealed these final decrees to the U.S. Supreme Court.
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Issue:
Does a law authorizing a board to set minimum wages for women in the District of Columbia violate the Due Process Clause of the Fifth Amendment's protection of the liberty to contract?
Opinions:
Majority - Justice Sutherland
Yes, the law violates the Due Process Clause of the Fifth Amendment. The right to contract about one's own affairs, including the price of one's labor, is a fundamental liberty protected by the Constitution. While this freedom is not absolute, it is the general rule, and legislative restraint is the exception, justifiable only by exceptional circumstances. This statute is simply a price-fixing law for adult women who are legally as capable of contracting for themselves as men. It differs from previously upheld regulations, such as those setting maximum hours for health reasons, because wages are the 'heart of the contract.' The statute's standard, based on an employee's needs, is impermissibly vague and one-sided, ignoring the value of the service to the employer and the employer's ability to pay. It arbitrarily shifts a societal burden to employers by forcing them to pay for something—the employee's subsistence—that has no causal connection to their business or the employment contract.
Dissenting - Chief Justice Taft
No, the law does not violate the Due Process Clause. Legislatures are entitled to address the problem of 'sweating' employers who take advantage of the unequal bargaining power of low-wage employees. There is no substantive constitutional distinction between regulating maximum hours and minimum wages; both are key terms of the employment contract, and restricting one is not inherently a greater interference than restricting the other. Low wages can be as detrimental to the health and morals of workers as long hours. The Court's previous decision in Muller v. Oregon, which upheld maximum hour laws for women based on physical differences, should control this case, as the Nineteenth Amendment did not eliminate these physical differences that justify protective legislation.
Dissenting - Justice Holmes
No, the law is a valid exercise of legislative power. The 'liberty of contract' is not absolute and is subject to numerous restrictions that have been upheld, such as usury laws, insurance rate regulations, and maximum hours laws. There is no meaningful difference in the degree of interference with liberty between regulating hours and regulating wages; the bargain is equally affected whichever half is regulated. The Court's role is not to judge the economic wisdom of a law but to determine if a reasonable person could believe it serves a legitimate public purpose. Since many reasonable people and governments believe minimum wage laws are effective means to protect public health and morality, the Court should not substitute its own economic dogma for that of the legislature.
Analysis:
This case represents a high point for the 'Lochner era' of jurisprudence, where the Supreme Court used the doctrine of substantive due process and 'liberty of contract' to strike down economic regulations. By invalidating minimum wage laws for women, the decision created a significant constitutional barrier to Progressive Era labor reforms for over a decade. The ruling reinforced a view of the Due Process Clause as a protector of laissez-faire economic principles against legislative interference. The decision was ultimately overruled by West Coast Hotel Co. v. Parrish in 1937, marking the end of the Lochner era and a shift toward greater judicial deference to economic legislation.
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