Alaska Packers’ Association v. Domenico

Facts

On March 26, 1900, a group of fishermen (plaintiffs) entered into a written contract with Alaska Packers’ Association (“APA”) (defendant) to sail from San Francisco to Pyramid Harbor, Alaska. The fishermen agreed to catch red salmon en route to Alaska in exchange for $50 plus two cents for each red salmon he caught. APA contracted with other fishermen, who were to be paid $60 plus two cents for each red salmon he caught. The fishermen stopped work aboard the ship and told the superintendent that they demanded a pay increase of $100 each for their services. APA had already invested $150,000 in a salmon cannery, the fishing season was short, and they were in remote waters. So, on May 22, 1900, APA’s superintendent yielded to the fishermen’s demands. The superintendent’s clerk drafted new contracts that paid the fishermen the sum of $100, which were signed by the fishermen. Upon their return to San Francisco, APA paid the fishermen according to their original contracts from March 26. The fishermen sued APA.