--- title: "West Coast Hotel v. Parrish | Constitutional Law I" description: "West Coast Hotel v. Parrish is the 1937 case upholding minimum wage laws and marking the Court's shift away from Lochner-era economic liberty." canonical: "https://fiveable.me/constitutional-law-i/key-terms/west-coast-hotel-v-parrish" type: "key-term" subject: "Constitutional Law I" unit: "Unit 16" --- # West Coast Hotel v. Parrish | Constitutional Law I ## Definition West Coast Hotel v. Parrish is the 1937 Supreme Court case that upheld a state minimum wage law under the state's police power. In Constitutional Law I, it marks the break from the Lochner Era's strong protection of freedom of contract. ## What It Is West Coast Hotel v. Parrish is the Supreme Court case that said a state can require employers to pay a minimum wage, even when the employer argues that contract freedom should let the parties set wages however they want. In Constitutional Law I, the case is remembered as the point where the Court backed away from the Lochner Era and gave states more room to regulate the economy for worker protection. The dispute came from Washington state, which had passed a minimum wage law for women. A hotel challenged the law, saying it violated the constitutional idea that employers and workers should be free to make their own bargains. The Court rejected that view and held that freedom of contract is not absolute when the state is acting to protect health and welfare. That shift matters because it changes the constitutional baseline for economic regulation. Before this case, the Court often treated wage and labor laws as suspicious if they interfered with private contracts. After this case, the Court became much more willing to uphold laws that regulate working conditions, so long as the government could point to a legitimate public purpose. The case is often read together with the New Deal era more broadly, because it shows the Court accepting a stronger role for government in addressing economic inequality and labor conditions. It does not mean states can regulate anything any way they want. It means courts stopped treating economic liberty as a near-automatic reason to strike down labor laws. A useful way to think about West Coast Hotel is that it changed the question from "Did the law interfere with contract freedom?" to "Does the state have a rational reason to regulate here?" That is why the case sits right next to the rational basis approach in constitutional law discussions. It is a turning point for police powers, labor regulation, and the Court's attitude toward substantive due process in the economic sphere. ## Why It Matters West Coast Hotel v. Parrish matters because it explains why modern constitutional law usually gives states wide latitude over economic regulation. If you are reading cases about minimum wages, labor standards, or business rules, this is the moment when the Court stopped treating those laws as presumptively unconstitutional just because they affected contracts. The case also helps you spot the difference between the Lochner Era and the post-Lochner approach. In Lochner-style reasoning, the Court was quick to see economic regulation as an attack on liberty of contract. In West Coast Hotel, the Court accepted that the state can protect workers from unfair bargaining conditions, especially when the legal system recognizes unequal bargaining power between employers and employees. You also see the case whenever a professor asks how courts evaluate social and economic legislation. It sits behind the more deferential standard you usually associate with rational basis review. So if a law sets wage floors, licensing rules, or other labor protections, this case is part of the constitutional backdrop that makes those laws easier to defend. It is also a good anchor point for understanding how constitutional doctrine can change without a new amendment. The text of the Constitution did not change in 1937, but the Court's view of what the Due Process Clause protects did. That is a recurring theme in Constitutional Law I, and this case is one of the clearest examples. ## Connections ### [Lochner Era](/constitutional-law-i/key-terms/lochner-era) West Coast Hotel v. Parrish is usually taught as the case that helped end the Lochner Era's strong protection of economic liberty. Instead of treating freedom of contract as almost sacred, the Court became more accepting of laws that regulate wages and working conditions. If you are comparing eras, Lochner shows the old approach and West Coast Hotel shows the turn toward deference. ### [Rational Basis Test](/constitutional-law-i/key-terms/rational-basis-test) This case fits the rational basis style of review because the Court accepted that Washington had a legitimate reason to set a minimum wage. The state did not have to prove the law was perfect, only that it reasonably served worker welfare. That makes the case a good example of how low-level judicial review works in economic regulation cases. ### [Substantive Due Process](/constitutional-law-i/key-terms/substantive-due-process) Freedom of contract was once treated as part of substantive due process, meaning the Due Process Clause protected it as a liberty interest. West Coast Hotel narrowed that idea in the economic sphere by saying the Constitution does not freeze wage bargaining rules in place. If you are tracing doctrine, this case shows substantive due process losing force in labor and economic regulation. ### Police Powers The decision reinforces state police powers, especially the power to regulate for public welfare. Minimum wage laws are not just about economics in the abstract, they are justified as part of a state’s authority to protect workers and reduce harmful conditions. That makes this case a strong example of how police powers can reach into the labor market. ## On the AP Exam A case brief question may ask you to identify West Coast Hotel v. Parrish from facts about a state minimum wage law and a challenge based on freedom of contract. The move is to connect the facts to the Court's shift away from Lochner-era skepticism and explain that the law was upheld under state police powers. In an essay or short-answer prompt, use the case to show why economic regulation is usually reviewed deferentially. If the question is about substantive due process, this is your example of the Court backing away from using due process to protect a broad right to contract in wage disputes. If you are comparing cases, pair it with Lochner v. New York to show the doctrinal change. For a class discussion or issue spotter, mention the worker-protection rationale and the Court's willingness to accept unequal bargaining power as a real problem. That is often the most useful sentence you can write about this case. ## West Coast Hotel v. Parrish vs Lochner v. New York These cases are easy to mix up because both involve economic regulation and freedom of contract. Lochner struck down a labor regulation and reflected the Court's older, more aggressive approach to reviewing state interference with the market. West Coast Hotel upheld a minimum wage law and is usually treated as the doctrinal shift away from that older view. ## Key Takeaways - West Coast Hotel v. Parrish upheld a state minimum wage law and let states regulate wages under their police powers. - The case marks the Court's break from the Lochner Era's strong protection of freedom of contract. - It shows the Court becoming more deferential to economic and labor regulation. - The decision is a major example of substantive due process narrowing in the economic sphere. - If a law protects workers and has a reasonable public purpose, this case supports the state's authority to defend it. ## FAQs ### What is West Coast Hotel v. Parrish in Constitutional Law I? It is the 1937 Supreme Court case that upheld a Washington minimum wage law for women. In Constitutional Law I, it is the classic example of the Court moving away from Lochner-era freedom of contract thinking and toward more deference to state economic regulation. ### Why is West Coast Hotel v. Parrish associated with the end of the Lochner Era? Because the Court stopped treating wage regulation as a presumptive violation of liberty of contract. After this case, the Court was much more willing to let states regulate labor conditions when they could point to worker welfare or another legitimate public purpose. ### How does West Coast Hotel v. Parrish relate to police powers? It shows that police powers include the ability to regulate economic activity when the state is acting to protect the public welfare. Minimum wage laws are a good example because they are justified as protecting workers from harmful labor conditions and unequal bargaining power. ### Is West Coast Hotel v. Parrish about substantive due process? Yes, in the sense that it limits how far substantive due process protects economic liberty. The case does not erase due process review, but it narrows the idea that freedom of contract is a constitutionally protected right strong enough to defeat most labor laws. ## Related Study Guides - [16.3 State Police Powers and Economic Regulation](/constitutional-law-i/unit-16/state-police-powers-economic-regulation/study-guide/0df49zn463Ba34mE) ## About This Document Canonical Fiveable pages are available as Markdown at the same path plus `.md`. - [llms.txt](https://fiveable.me/llms.txt): index of Fiveable's sections and URL patterns - [llms-full.txt](https://fiveable.me/llms-full.txt): complete subject and unit listing - [MCP server](https://fiveable.me/mcp): call Fiveable as tools instead of fetching pages (`https://fiveable.me/api/mcp`) - [MCP server for AP teachers](https://fiveable.me/mcp/teachers): a teacher's classes, assignments and AP-rubric grading (`https://fiveable.me/api/mcp/teacher`) ## Structured Data ```json {"@context":"https://schema.org","@graph":[{"@type":"LearningResource","@id":"https://fiveable.me/constitutional-law-i/key-terms/west-coast-hotel-v-parrish#resource","name":"West Coast Hotel v. 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