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Keywords

contractplaintiffappealregulationdue process

contractstatutewillcorporationdue processappellee

Related Cases

Adkins v. Children’s Hospital of the District of Columbia, 261 U.S. 525, 43 S.Ct. 394, 67 L.Ed. 785, 24 A.L.R. 1238

Facts

The Children's Hospital employed women at wages that were sometimes below the minimum wage set by the Wage Board established under the Act of September 19, 1918. The hospital sought to restrain the board from enforcing its order, claiming it violated the Constitution. In a separate case, a woman employed as an elevator operator was also affected by the board's order, which forced her employer to terminate her employment due to the minimum wage requirements. Both cases were dismissed by the Supreme Court of the District, leading to appeals.

The appellee in the first case is a corporation maintaining a hospital for children in the District. It employs a large number of women in various capacities, with whom it had agreed upon rates of wages and compensation satisfactory to such employees, but which in some instances were less than the minimum wage fixed by an order of the board made in pursuance of the act.

Issue

The main legal issue was whether the Act of September 19, 1918, which fixed minimum wages for women and children, was constitutional under the due process clause of the Fifth Amendment.

The statute now under consideration is attacked upon the ground that it authorizes an unconstitutional interference with the freedom of contract included within the guaranties of the due process clause of the Fifth Amendment.

Rule

The court applied the principle that the right to contract is part of individual liberty protected by the due process clause, and any legislative interference with this right must be justified by exceptional circumstances.

The right to contract about one's affairs is a part of the liberty of the individual protected by this clause is settled by the decisions of this court and is no longer open to question.

Analysis

The court analyzed the Act and determined that it constituted an unconstitutional interference with the freedom of contract. It noted that the Act did not address any public interest or emergency situation and merely imposed wage-fixing regulations on private employment relationships. The court emphasized that both parties in the employment relationship were legally capable of contracting and should be free to negotiate wages without government interference.

The essential characteristics of the statute now under consideration, which differentiate it from the laws fixing hours of labor, will be made to appear as we proceed. It is sufficient now to point out that the latter, as well as the statutes mentioned under paragraph (3), deal with incidents of the employment having no necessary effect upon the heart of the contract; that is, the amount of wages to be paid and received.

Conclusion

The court concluded that the Act was unconstitutional as it arbitrarily interfered with the liberty of individuals to contract freely, leading to the affirmation of the lower court's decision.

The court concluded that the Act was unconstitutional as it arbitrarily interfered with the liberty of individuals to contract freely.

Who won?

The plaintiffs, including the Children's Hospital and the individual employee, prevailed in the case because the court found the Act unconstitutional, thus protecting their right to contract freely.

The appellee in the first case is a corporation maintaining a hospital for children in the District.

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