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In 1918, Congress enacted a law which guaranteed a minimum wage to women and children employed in the District of Columbia. This case was decided together with Children's Hospital v. Lyons.

Did the law interfere with the ability of employers and employees to enter into contracts with each other without assuring due process of law, a freedom guaranteed by the Fifth Amendment?

The Court found that upholding the statute would dangerously extend the police power of the state and, thus, found it unconstitutional. Justice Sutherland recognized that the freedom of individuals to make contracts is not absolute and curtailments of this right may be justified in the face of "exceptional circumstances." However, in this case, the statute's implementation procedures were overly vague and did not act to regulate the character or method of wage payments, or the conditions and hours of labor, areas in which regulation to protect the public welfare were legitimate. The Congress simply had enacted a "price-fixing law."