Adkins v. Children's Hospital

Adkins v. Children’s Hospital, 261 U.S. 525 (1923), is a landmark decision of the United States Supreme Court.

Congress established a minimum wage for women in the District of Columbia. Children’s Hospital challenged the law, arguing that it violated the liberty of contract protected by the Due Process Clause. The government defended the law as a valid exercise of the police power to protect women’s health.

Significance

Justice Sutherland’s 5-3 opinion struck down the minimum wage law, holding that the Nineteenth Amendment (granting women the right to vote) had eliminated the need for special protections for women recognized in Muller. Since women were now legally equal to men, the same liberty of contract that protected men under Lochner applied equally to women. Adkins was overruled by West Coast Hotel v. Parrish (1937), which upheld a Washington state minimum wage law and marked the end of the Lochner era.

Category

US Federal Case Law