Facts of the Case
In 1918, Congress enacted a law guaranteeing a minimum wage to women and children employed in the District of Columbia. D.C.’s Children’s Hospital, which employed many women, sought an injunction against enforcing the law. The injunction was denied in the trial court but granted in the intermediate appellate court.
Did the minimum wage law violate the Due Process Clause of the Fifth Amendment?
The majority struck down the minimum wage law as unconstitutional. The Court relied on Lochner v. New York, which struck down a law limiting bakers’ working hours under the Due Process Clause, which they believed contained a right of “freedom to contract.” In Adkins, the Court reasoned that the same reasoning extended to a minimum wage law. Employer and employee, according to the majority, had a constitutional right to contract in whatever manner they pleased. Thus, the minimum wage law unjustly interfered with the freedom to contract. Moreover, the Court reasoned that women do no merit greater protection than men.
In dissent, Justices William Howard Taft, Oliver Wendell Holmes, Jr., and Edward T. Sanford argued that Congress had the policing power to correct recognizable evils. This position was later adopted in West Coast Hotel Company v. Parrish (1937), when the Court ruled that some government intervention in contracts between employers and employees can be constitutional.