Alaska Packers’ Association v. Domenico
United States Court of Appeals for the Ninth Circuit · Decided May 26, 1902 · Core case
Full citation
Alaska Packers’ Ass’n v. Domenico, 117 F. 99 (9th Cir. 1902).
VerifiedQuotes, pinpoints and citation checked word for word against the opinion; facts checked against the opinion before publication. October 20, 2026.
Alaska Packers' Association
salmon canning companyappellant
Domenico et al.
fishermen and sailorslibelants
Brief
Facts
On March 26, 1900, in San Francisco, the fishermen signed a written contract with the Alaska Packers' Association to sail to Pyramid Harbor, Alaska, and back, and to work as sailors and fishermen during the 1900 fishing season for $50 for the season plus two cents for each red salmon they helped catch. On April 15, 1900, twenty-one of them signed shipping articles on the vessel Two Brothers covering the same work, for $60 for the season plus two cents per salmon. They arrived at Pyramid Harbor early in April and began unloading the vessel and fitting up the cannery, in which the company had about $150,000 invested. On May 19 they stopped work in a body and demanded $100 each instead, threatening to quit entirely and return to San Francisco. Because the place was remote and the season short and just opening, the company could not get other men. On May 22 the company's superintendent yielded, had his clerk copy the San Francisco contracts substituting $100, and the men signed before a shipping commissioner, though the superintendent testified he told them he had no authority to make or alter contracts. On the return to San Francisco the company refused to pay other than under the original contracts; the men took that pay and released or receipted in full.
Issue
Assuming the company's superintendent had authority to make the contract of May 22, was the company's promise of higher pay supported by a sufficient consideration?
Holding
Even assuming the superintendent was authorized to make the contract of May 22 and executed it for the company, the company's consent, if given, was without consideration, because it rested solely on the men's agreement to render the exact services, and none other, that they were already under contract to render. The judgment for the libelants was reversed.
IRAC
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