Brief Fact Summary. This case involves a contract modification to a services contract where the workers demanded increased compensation to perform the same duties as specified in the original contract.
Synopsis of Rule of Law. When one is contractually obligated to perform certain duties, a demand for increased compensation to perform these same duties is not supported by sufficient consideration.
Issue. Is a contract modification, which seeks to increase wages to be paid for the same duties as stated in the original contract, valid?
Held. No. Judgment reversed. This Court found that a demand for increased wages where there is a pre-existing duty to perform certain obligations, is not supported by consideration.
Discussion. The court found that the Plaintiffs were already obligated by contract to perform their duties. These duties had not changed in anyway, as the original contract stated that they were to travel by vessel to Alaska. Therefore, no consideration existed to support Plaintiffs’ demand for increased wages. (The lower court had rejected the Plaintiffs’ argument that the fishing nets were rotted, entitling them to increased wages.) The court also reasoned that allowing such a modification would encourage men to abandon their contractual obligations in bad faith.