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Adkins v. Children's Hospital
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| Adkins v. Children's Hospital | |
| Reference: 261 U.S. 525 | |
| Term: 1923 | |
| Important Dates | |
| Argued: March 14, 1923 Decided: April 9, 1923 | |
| Outcome | |
| United States Court of Appeals for the District of Columbia Circuit affirmed | |
| Majority | |
| George Sutherland • Joseph McKenna • Willis Van Devanter • James Clark McReynolds • Pierce Butler | |
| Dissenting | |
| William Howard Taft • Oliver Wendell Holmes • Edward Terry Sanford | |
Adkins v. Children's Hospital is a case that was decided on April 9, 1923, by the United States Supreme Court holding that establishing a minimum wage for women violated their freedom of contract. The case concerned whether it was constitutional to enforce a minimum wage for women. The Supreme Court affirmed the decision of the United States Court of Appeals for the District of Columbia Circuit.[1][2][3]
Why it matters: The Supreme Court's decision in this case established that a minimum wage for women violated their constitutional right to freedom of contract. To read more about the impact of Adkins v. Children's Hospital click here.
Background
In 1918, Congress established a law saying that women working “in a place where food is served” must receive no less than $16.50 a week and those working “in a laundry” must receive no less than $15.00 per week in wages. Children’s Hospital, which employed many women at much lower rates, sued as a result.[3]
In another case, a woman named Willie Lyons was an elevator worker who was earning $35.00 per month with two meals daily. The new minimum wage law forced an increase in wage to $16.50 per week for all female workers in the hotel industry. The increase in wage meant that the hotel could no longer afford to employ her, and she lost her job. She sued to enjoin the District minimum wage board from enforcing the minimum wage law.[4]
Oral argument
Oral argument was held on March 14, 1923. The case was decided on April 9, 1923.[1]
Decision
The Supreme Court decided 5-3 to affirm the decision of the United States Court of Appeals for the District of Columbia Circuit. Justice George Sutherland delivered the opinion of the court. Chief Justice William Howard Taft wrote a dissenting opinion. Justice Louis Brandeis did not participate in the vote since his daughter worked as a secretary for the District's minimum wage board.[2][5]
Opinions
Opinion of the court
Justice George Sutherland, writing for the court, cited Lochner v. New York (1905) and addressed the law's violation of the Fifth Amendment’s Due Process Clause. The Court went on to explain that this law went against the right to private bargaining and that the law was “an arbitrary interference with the liberty of contract which no government can legally justify in a free land." In addition to this reasoning, the Court pointed out that the law gave special treatment to women and excluded men. Because women had recently gained the right to vote, the court argued that a separate minimum wage was unnecessary.[3]
| “ | We cannot accept the doctrine that women of a mature age . . . may be subjected to restrictions upon their liberty of contract which could not lawfully be imposed in the case of men under similar circumstances.[6] | ” |
| —George Sutherland, majority opinion in Adkins v. Children's Hospital[5] | ||
Dissenting opinion
Chief Justice William Howard Taft dissented, arguing that Congress should have the authority to correct what they perceive as wrongs and posited that some government intervention in contracts is constitutional.[1]
| “ | Legislatures in limiting freedom of contract between employee and employer . . . proceed on the assumption that employees, in the class receiving less pay, are not upon a full level of equality of choice with their employers and . . . are prone to accept pretty much anything that is offered. They are peculiarly subject to the overreaching of the harsh and greedy employer. The evils of the sweating system and long hours and low wages which are characteristic of it are well known.[6] | ” |
| —William Howard Taft, dissenting opinion in Adkins v. Children's Hospital[5] | ||
Impact
| Federalism |
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| •Key terms • Court cases •Major arguments • State responses to federal mandates • Federalism by the numbers • Index of articles about federalism |
- See also: West Coast Hotel Co. v. Parrish
Adkins v. Children's Hopsital established that a minimum wage for women would violate their freedom of contract, however, this ruling was later overturned by West Coast Hotel Co. v. Parrish.[2][7]
Reactions to the ruling varied. Union leaders were outraged over the decision and the District of Columbia's minimum wage board thought minimum wage should continue to be enforced, despite the Court’s decision. Several senators, angry over the decision, proposed limiting the power of the Supreme Court. Ideas included to require the agreement of seven justices or two-thirds votes in an opinion. One senator even suggested that Congress should have the power to overrule the court with a law after unpopular decisions.[5]
See also
External links
- Full text of case syllabus and opinions (Justia)
- Supreme Court of the United States
- Search Google News for this topic
Footnotes
- ↑ 1.0 1.1 1.2 Oyez, "Adkins v. Children's Hospital of D.C.," accessed July 28, 2022
- ↑ 2.0 2.1 2.2 Justia, "Adkins v. Children's Hosp. 261 U.S. 525 (1923)," accessed July 28, 2022
- ↑ 3.0 3.1 3.2 PBS, Landmark Cases: Adkins v. Children’s Hospital, accessed December 12, 2013
- ↑ Jrank, Adkins v. Children’s Hospital – Significance, accessed December 12, 2013
- ↑ 5.0 5.1 5.2 5.3 Jrank, Adkins v. Children’s Hospital – But Are They Constitutional, accessed December 12, 2013
- ↑ 6.0 6.1 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
- ↑ Yale Law Journal, “West Coast Hotel’s Place in American Constitutional History,” accessed December 10, 2013
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