Adkins v. Children's Hospital

Adkins v. Children's Hospital was a 1923 decision of the Supreme Court of the United States that struck down a federal minimum wage law for women in the District of Columbia. The Court held that the law violated the freedom of contract protected by the due process clause of the Fifth Amendment, reasoning that the Nineteenth Amendment's extension of political equality to women removed the special justification earlier decisions had used to uphold protective labor legislation for women. The ruling relied on the same liberty of contract doctrine associated with Lochner v. New York and drew a sharp dissent from Chief Justice William Howard Taft and Justice Oliver Wendell Holmes Jr., who argued that wage regulation was a legitimate exercise of the police power. The decision was formally overruled fourteen years later in West Coast Hotel Co. v. Parrish, which upheld a Washington state minimum wage law and marked the end of the Lochner era of substantive due process review of economic regulation.