In August 1933, Elsie Parrish started making beds at the Cascadian Hotel in Wenatchee, Washington. She was in her forties, married to Ernest Parrish, with six children already grown and a grandchild of her own. The job paid 22 cents an hour: sweeping carpets, scrubbing bathrooms, dusting furniture in rooms she would never sleep in. By 1935 her rate had climbed to 25 cents, which came to $12 for a 48-hour week. The state of Washington had already decided that wasn’t enough. Its Industrial Welfare Committee, under a 1913 law that let it set wage floors for women and minors, had fixed the minimum for hotel work at $14.50 for the same 48 hours. Parrish’s employer paid her the lower number anyway, for two years, and nobody stopped it.

When Parrish left the Cascadian in 1935, she did the arithmetic. She was owed $216.19, the accumulated gap between what Washington law said a hotel had to pay a chambermaid and what she had actually been handed. The West Coast Hotel Company, which owned the Cascadian, offered her $17 to make it go away. She turned it down and hired C.B. Conner, a young Wenatchee lawyer, to sue for the rest.

The law the hotel was betting on

The hotel’s confidence had a name: Adkins v. Children’s Hospital, decided by the Supreme Court in 1923. That case struck down a District of Columbia law setting minimum wages for women, on the theory that wages were the core of a contract between employer and employee, and the Constitution’s due process clause protected each side’s liberty to strike whatever bargain it wanted. Justice George Sutherland wrote that a wage law “ignores all the other, and, in some ways, more important circumstances,” treating the worker’s need for subsistence as if it were the employer’s problem to solve, and not the market’s. Under Adkins, a state could limit how many hours a woman worked, since that touched health, but not what she was paid for those hours, since that touched contract. Washington’s minimum wage board had been operating for two decades under a precedent that said, in effect, the very thing it did was unconstitutional. Parrish’s suit forced the question straight at it.

Washington’s own supreme court sided with Parrish in 1936, distinguishing her case from Adkins on narrow grounds. West Coast Hotel appealed to the United States Supreme Court, confident that Adkins would settle it the way it had settled every wage case since 1923. For fourteen years it had. Minimum wage boards in a dozen states operated under the same threat: any employer willing to litigate could point to Adkins and win. Washington kept its board running anyway, betting that Parrish’s case, or one like it, would eventually force the Court to look at the question again rather than cite its own prior answer. The justices heard argument on December 16 and 17, 1936.

What actually happened at conference

Two days after argument, on December 19, 1936, the nine justices met in conference and voted. This is the detail the popular version of the story leaves out, and it matters more than anything the opinion itself says. The phrase most people know for this case is “the switch in time that saved nine”: the idea that Justice Owen Roberts, previously a reliable vote against New Deal-style economic regulation, flipped his position because Franklin Roosevelt had just proposed packing the Court with additional justices, and Roberts caved to save the institution from being politically neutered.

The chronology does not support it. Roosevelt announced his court-packing plan on February 5, 1937. Roberts had already voted, at that December 19 conference, to uphold Washington’s minimum wage law and to overrule Adkins, nearly seven weeks before Roosevelt’s proposal existed in public. The historian Barry Cushman, working from the justices’ own conference notes and docket books in his 1998 study Rethinking the New Deal Court, laid this timeline out in detail: the vote that decided West Coast Hotel was cast before the threat that supposedly produced it. What did line up with the court-packing fight was the announcement of the decision, handed down March 29, 1937, seven weeks after Roosevelt’s plan went public and in the middle of the fiercest political fight over the Court’s composition in a century. The opinion’s release looked like capitulation. The vote behind it was not.

Why the delay between vote and announcement, then, if not political calculation? The Court held a second vacancy-related complication and an opinion to write, and Chief Justice Charles Evans Hughes took the assignment himself. None of that required softening the outcome for outside consumption. It required only the ordinary months a majority opinion takes to draft, circulate, and answer a dissent. The dissent came from Sutherland, the author of Adkins, who wrote that Washington’s statute was “in every substantial respect identical with the statute involved in the Adkins Case” and that the majority had simply decided to feel differently about it.

What the majority actually said

Hughes did not pretend liberty of contract was fiction. He wrote that “liberty under the Constitution is thus necessarily subject to the restraints of due process, and regulation which is reasonable in relation to its subject and is adopted in the interests of the community is due process.” Freedom of contract, in his phrasing, was “qualified, and not an absolute, right.” The opinion leaned on economic reality rather than abstract doctrine: employers with unequal bargaining power could depress wages below subsistence, Hughes wrote, and the public then absorbed the cost of that underpayment through relief and charity. A state legislating a wage floor was not inventing a new power. It was declining to let one class of workers be a subsidy for another.

Adkins was named and overruled, not distinguished or left to fade unmentioned. The opinion said outright that the earlier case “should be, and it is, overruled.” That kind of direct reversal was rare enough in 1937 that legal commentators noticed it as much as the outcome itself. The constitutional argument against minimum wage law, seven decades in the making and unbroken since Lochner-era reasoning first took hold, ended in a single paragraph.

What happened to the money, and to Parrish

The Superior Court in Chelan County, before an appeal ever reached Olympia or Washington, D.C., had already found for Parrish under Judge W.O. Parr. After the U.S. Supreme Court’s ruling closed off the hotel’s last defense, Parrish collected her $216.19, two years after she had last cleaned a room at the Cascadian. By the time the decision came down, she was working at a laundry in Omak, sixty miles north, still doing the kind of physical work that minimum wage law exists to cover. She told a reporter she was glad the case had gone her way and intended to keep working. She then largely disappears from the historical record, no different from most people whose names end up on the front of a Supreme Court reporter.

The floor that outlasted the fight

West Coast Hotel did not invent the minimum wage. States had been experimenting with wage boards since the 1910s, and Congress would not pass a national minimum wage until the Fair Labor Standards Act, signed June 25, 1938, extended a wage floor to men as well as women and set it in federal statute rather than in a patchwork of state boards. What Parrish’s case did was remove the one argument that could void all of it at once: that a wage floor, unlike an hours cap, was constitutionally off limits no matter what a legislature decided. Every minimum wage statute passed since, state or federal, has stood on the ground West Coast Hotel cleared. Nobody has seriously tried to reopen that constitutional question since 1937, which is its own kind of verdict on how settled it became.

A hotel maid earning 22 cents an hour did more to establish that floor than any single piece of federal legislation before FLSA. She did it by refusing a $17 check and insisting on $216.19, a sum small enough that no economist would call it structural and large enough that she would not let it go.