Alaska Packers' Ass'n v. Domenico
United States Court of Appeals for the Ninth Circuit
117 F. 99 (1902)
Sailors (plaintiffs) working under existing contracts with APA (defendant) to fish in Alaska stopped working mid-season and refused to resume unless paid $100 instead of their original $50 or $60; unable to hire replacements, an APA representative signed a new contract at the higher rate, though he warned he lacked authority to alter the original terms. Back in San Francisco, APA paid only the original contract amounts, and the sailors sued for the difference, claiming APA had supplied defective fishing nets (a claim the trial court rejected as unproven) while otherwise ruling for the sailors.
Whether a new agreement is enforceable when one party agrees under it to do no more than it was already obligated to do under an existing contract.