Adkins v. Children’s Hospital: A Legal Overview

Historical Event

Date

1923

Location

District of Columbia, United States

Result

Policy enacted or repealed

Introduction

Adkins v. Children’s Hospital (1923) was a pivotal U.S. Supreme Court case challenging a minimum wage law for women in the District of Columbia, enacted by Congress in 1918 to protect vulnerable workers. The hospital paid wages below the law’s minimum and argued this violated the Fifth Amendment’s due process right to freedom of contract. In a 6-3 decision, the Court ruled the law unconstitutional, emphasizing that the government infringed upon the liberty to contract freely. This case is significant for shaping early 20th-century labor rights and was later overturned in 1937, marking a shift toward accepting wage regulation.

Background and historical context of Adkins v. Children’s Hospital

In the early 20th century, the U.S. Congress sought to protect vulnerable workers by establishing a minimum wage law specifically for women and children in the District of Columbia. This 1918 law created a Wage Board tasked with setting appropriate wages to prevent exploitation and poverty. However, Children's Hospital, which employed women at wages lower than those mandated, challenged the law, claiming it violated the Fifth Amendment’s due process protection by restricting freedom of contract. The case reached the Supreme Court in 1923, amid legal debates during the Lochner era about economic regulation versus individual rights. The Court ruled that the law was an unconstitutional interference with employers’ and employees’ rights to freely negotiate contracts, viewing it as unnecessary after women gained political equality through the Nineteenth Amendment. This decision reflected the tension between protective labor laws and constitutional liberties, a conflict later reconsidered as economic and social policies evolved.

Details of the case proceedings

The case of Adkins v. Children’s Hospital followed a detailed judicial process involving several courts before reaching the Supreme Court.

Initial filings and lower courts

The matter began when Children’s Hospital, located in the District of Columbia, challenged the federal Minimum Wage Act, which set minimum wages for women and minors. The hospital employed women whose wages were below the statutory minimum, but these wages were agreed upon mutually and to the parties’ satisfaction. The hospital filed suit in the federal district court seeking to enjoin the enforcement of the minimum wage law, claiming that it infringed on their Fifth Amendment right to freely contract.

The federal district court initially denied the injunction requested by Children’s Hospital, allowing the minimum wage law to be enforced. Following this decision, the case was appealed to the Court of Appeals for the District of Columbia. The appeals court first affirmed the lower court’s ruling but then, after a rehearing, reversed it. This sequence reflected some judicial disagreement about the constitutionality of the minimum wage law and its interference with contractual freedom.

Journey to the Supreme Court

Following the Court of Appeals’ reversal of the district court’s original denial of an injunction, the case was taken up by the United States Supreme Court. The appellants, including Jesse C. Adkins, the federal official in charge of administering the minimum wage program, asked the Supreme Court to review the constitutionality of the Minimum Wage Act as it applied to women workers.

Arguments before the Supreme Court focused on the balance between Congress’s power to regulate labor conditions and individuals’ rights to contract freely under the Due Process Clause of the Fifth Amendment. The petitioners contended that mandating minimum wages for women was an unconstitutional intrusion on liberty.

Supreme Court ruling and opinions

In 1923, the Supreme Court delivered its verdict. The Court, in a 6-3 decision, reversed the lower court’s judgment that had upheld the minimum wage law. Writing for the majority, Justice George Sutherland emphasized freedom of contract and argued that the minimum wage legislation improperly interfered with women’s right to negotiate their own wages. The Court declared the Minimum Wage Act unconstitutional. The majority opinion stressed that government intervention at this level violated personal liberty.

The dissent, penned by Chief Justice William H. Taft and others, argued against overturning the law. They saw the minimum wage as comparable to other labor regulation measures and expressed concern about limiting Congress’s power to enact protective labor standards.

The decision thus marked a significant judicial event in the early constitutional debates over labor regulation and economic rights. Throughout the proceedings, Children’s Hospital acted as the plaintiff defending employer rights, while Adkins represented federal enforcement aiming to secure minimum wage protections for women.

Key facts include: the initial denial then reversal of injunctions, the Supreme Court’s invalidation of the law in a 6-3 ruling, and the pointed contrast between majority and dissenting opinions on labor regulation and contract freedom.

Outcomes of the case decision

The outcome of Adkins v. Children’s Hospital (1923) was that the U.S. Supreme Court declared the federal minimum wage law for women unconstitutional, reversing the lower court’s decision. The Court ruled that the Minimum Wage Act violated the liberty of contract protected by the Due Process Clause of the Fifth Amendment. In other words, it found that the law unlawfully interfered with the ability of employers and employees to freely agree on wages. This decision was a key example of the Lochner era, when the Court often struck down economic regulations as improper government interference. However, the ruling was later overturned in 1937 by West Coast Hotel Co. v. Parrish, which upheld minimum wage laws and marked a shift toward allowing more government labor protections. The case helped define limits on governmental power over the economy during its time.

Long-term effects on labor laws and regulations

Adkins v. Children’s Hospital significantly impacted labor laws by reinforcing the freedom of contract doctrine and limiting early minimum wage regulations. The 1923 Supreme Court ruling struck down a minimum wage law for women in the District of Columbia, emphasizing that government interference with wage-setting violated the Fifth Amendment's due process clause. This decision reflected the Court's commitment to laissez-faire economic principles, rolling back progressive labor reforms during the 1920s and early 1930s. However, its influence waned after 1937 when the ruling was overturned by West Coast Hotel v. Parrish, which allowed more government regulation of labor conditions, shaping modern labor law.