Alaska Packers' Association v. Domenico

Case brief summary

Facts

Fishermen contracted for set wages to work in Alaska, then refused to continue unless paid more, knowing no replacements could be found. The manager agreed, but the company later paid only the original amount, and workers sued for the difference.

Procedural history

The trial court, sitting without a jury in admiralty, ruled in favor of the workers and enforced the higher-pay agreement. The company appealed to the United States Court of Appeals for the Ninth Circuit.

Issue

Was the company's later promise to pay the workers more money, for doing the exact same work they were already contractually required to do, supported by valid consideration so that it could be enforced?

Holding

The new promise to pay more money was not supported by valid consideration and therefore could not be legally enforced. The court reversed the lower court's judgment and ordered judgment entered for the company.

Reasoning

The workers offered nothing new since they only kept doing their already-required job, essentially forcing extra pay by exploiting the company's bind, which courts shouldn't reward.

Opinions

Majority (Ross): A promise to pay extra for work already legally owed under contract has no consideration and cannot be enforced, even if obtained through coercive threats to quit.