Alaska Packers’ Ass’n v. Domenico

United States Court of Appeals, Ninth Circuit, 1902.

117 F. 99.

Dawson, pp. 569-572

Facts: The packing company hired some dudes from San Francisco to go up to Alaska and work on salmon fishing and canning. They at first signed an agreement to get $50 each for the season. Before they left, they signed another agreement giving them $60 each. Then when they got up to Alaska, they refused to work unless they were promised $100 each. The guy in charge was forced to accede to their demands and make a new contract at the rate of $100 per person. He tried to tell them that he had no authority to make a new contract. When the dudes got back, they demanded their $100 each, but the company would only pay them under the terms of the contracts they signed before they left.

Issue: Was the contract made in Alaska supported by fresh consideration?

Rule: It’s not fair to coerce a party into giving a promise in exchange for doing something you were already bound to do anyway, and the law shouldn’t allow this.

Analysis: The court basically states the rule and then asserts that the result follows really fast.

Conclusion: The judgment of the court below is reversed.

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