Case Citator › Adkins v. Children's Hospital of Columbia

Adkins v. Children's Hospital of Columbia

Is it still good law? What later courts have actually done to this case.

Overruled
Court
Supreme Court of the United States
Citation
261 U.S. 525
Decided
Confirmed treatments
4
Flagged citations read
61 of 74
Citing cases (total)
468
Treatment dates
1937–1957

Status

Overruled
A reviewed court has overruled this case. Adkins v. Children's Hospital of Columbia was overruled by the Supreme Court in West Coast Hotel Co. v. Parrish. The Court rejected Adkins's constitutional bar to minimum-wage laws for women.
More on how this was screened

The 4 confirmed adverse treatments are listed below. Of the 74 flagged citations, 61 were read; the text of the other 13 could not be retrieved or did not contain the citation to Adkins, so they remain unread. Most other opinions merely report the West Coast Hotel history or discuss other precedents.

The treatments below are confirmed; unread citations could still change the overall status.
Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case, except the ones whose text could not be retrieved.

468 later cases cite Adkins v. Children's Hospital of Columbia; 74 of those citations sat close to treatment language and were flagged for reading; 61 of them have been read, and the text of 13 citing opinions could not be retrieved, so those remain unread. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

Relying on Adkins v. Children's Hospital of Columbia?

This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.

Treatments

Overruled

  • The Supreme Court expressly overruled Adkins's holding that minimum-wage legislation for women violates constitutional liberty of contract.

    West Coast Hotel Co. v. Parrish · Supreme Court of the United States · filed

    Our conclusion is that the case of Adkins v. Children’s Hospital, supra, should be, and it is, overruled.
    Read the full opinion on CourtListener →

Declined to follow

  • The Oklahoma Criminal Court of Appeals chose the minimum-price rule supported by West Coast Hotel and Nebbia and expressly rejected Adkins's contrary majority reasoning.

    Ex parte Herrin · Oklahoma Criminal Court of Appeals · filed

    Our judgment is in accord with the decisions of the Supreme Court of the United States in the West Coast Hotel Company Case and the Nebbia Case, and not with the majority opinion in the Adkins Case, and the decisions of the Supreme Court of California.
    Read the full opinion on CourtListener →

Criticized

  • The Supreme Court disapproved Adkins's liberty-of-contract approach while upholding Missouri's paid voting-leave law.

    Day-Brite Lighting, Inc. v. Missouri · Supreme Court of the United States · filed

    We could strike down this law only if we returned to the philosophy of the Lochner, Coppage, and Adkins cases.
    Read the full opinion on CourtListener →
  • The Supreme Court of New Jersey described Adkins's minimum-wage holding as unfortunate.

    New Jersey Restaurant Ass'n v. Holderman · Supreme Court of New Jersey · filed

    The distinction was there drawn to escape the unfortunate holding in Adkins v. Children's Hospital of District of Columbia, 261 U. S. 525, 43 S. Ct. 394, 67 L. Ed. 785 (1923), that freedom of contract foreclosed legislative prescription of minimum wages for women and minors.
    Read the full opinion on CourtListener →

Does this case still carry your argument?

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