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Contracts Keyed to Jimenez
Alaska Packers’ Ass’n v. Domenico
ProfessorMelissa A. Hale
CaseCast™ – "What you need to know"
Facts
In March 1900, a group of fishermen contracted with the Alaska Packers’ Association (APA) to work on a fishing boat during the salmon season. They agreed to fish for salmon, deliver their catch to APA’s cannery in Alaska, and return to San Francisco. The contract stipulated that each fisherman would be paid $50 plus two cents for each salmon caught. The following month, additional fishermen joined under similar terms but were offered $60 plus the same per-salmon rate. In May 1900, after arriving in Alaska, the fishermen collectively stopped working and demanded a new contract with a base pay of $100. Due to the short fishing season and the remote location, APA’s superintendent reluctantly agreed to the new terms to avoid a total loss of the season. However, once the work was completed, APA paid the fishermen according to the original contract terms. The fishermen then sued APA for breach of the revised contract, seeking the additional pay they had demanded. The U.S. District Court for the Northern District of California ruled in favor of the fishermen, but APA appealed.
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