Adkins V. Children's Hospital Case Brief

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Pages: 3

Adkins v. Children's Hospital 261 U.S. 525 (1923)

Facts
In 1918 Congress enacted a law that established the Minimum Wage Board of the District of Columbia and gave it authority to set minimum wages for women and children in Washington, D.C. The board ordered that restaurants and hospitals pay women workers a minimum of 34.5 cents per hour, $16.50 per week, or $71.50 per month because these rates would “supply the necessary cost of living to women workers to maintain them in good health and morals.” Children’s Hospital of the District of Columbia, refused to comply with the law and sued the Wage Board to enjoin the enforcement of the regulations because the hospital claimed they violated the Due Process Clause of the Fifth Amendment for not allowing them to enter into salary contracts with their employees. The case did not reach the Supreme Court until 1923. Jesse Adkins of the Wage Board argued that the Court should focus on the reasonableness of the law as safeguarding women and children form conditions that would
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Holding
Yes, 5-3 in favor of Children’s Hospital. Justice Sutherland wrote the majority opinion. Justice Brandeis did not participate.

Reasoning
1. The right of contract about one’s affairs is part of the liberty protected by the Due Process clause and is settled by past decisions of the Court.
2. While there is no such thing as absolute freedom of contract, but the freedom of contract is the general rule and the exercise of legislative authority to restrict is can be justified only with the existence of exceptional circumstances.
3. The Minimum Wage law is a price-fixing law confined to adult women who can contract for themselves as men can. The moral requirement implicit in any contract, that the amount to be paid and the service to be rendered shall bear some relation of just equivalence, is