Alaska Packers' Ass'n v. Domenico

117 F. 99 · Court of Appeals for the Ninth Circuit · 1902

Facts

Fishermen contracted to work for Alaska Packers' Association in Pyramid Harbor, Alaska. Upon arrival, they stopped work and demanded higher wages, threatening to quit. The company's superintendent, unable to find replacements, agreed to a new contract for increased pay, but the company later refused to honor it.

Issue

Was the second contract, promising increased wages for services the fishermen were already contractually obligated to perform, supported by sufficient consideration?

Holding

No, the court held that the second contract was without consideration and therefore unenforceable. The judgment of the lower court was reversed.

Rule

A promise to pay a party for doing that which they are already legally bound to do under an existing contract is without consideration and thus unenforceable. Performing a pre-existing contractual duty cannot serve as new consideration.

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Case brief last reviewed 2026-03-02. Prepared by CaseReader from the published opinion.