Adkins v. Children’s Hospital case brief

Adkins v. Children’s Hospital case brief summary
261 U.S. 525 (1923)

CASE SYNOPSIS

Appellant challenged a Court of Appeals for the District of Columbia decision which held that the Act of September 19, 1918, ch. 174, 40 Stat. 960, providing a fixed wage for female employees, was an unconstitutional exercise of state police power as it interfered with labor contracts involving private parties.

CASE FACTS
Appellant sought review of a lower court's determination that the Act of September 19, 1918 (Act), ch. 174, 40 Stat. 960, which fixed minimum wages for female employees in private employment, was an unconstitutional interference with the freedom to contract. The decision of the lower court was affirmed on appeal.

DISCUSSION

• The United States Supreme Court held that the Act interfered with U.S. Constitutional Amendment V guaranties, as the Act prevented private employers and employees from bargaining for the best contractual terms. 
• The Court also held that the wage fixed by the Act had no relation to the capacity of female employees but, rather, was an invalid exercise of state police power by attempting to establish an arbitrary amount necessary to provide a living for women. 
• Further, the Act required an employer to make an arbitrary payment to female employees without any causal connection to his business or the type of work the employee performed.

CONCLUSION

The Court affirmed the lower court's decision, holding that the act providing fixed minimum wages for female employees was an unconstitutional interference with the freedom to contract as the amount had no relation to the type of work involved or employee capacity and unjustly prevented bargaining for contractual terms.

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