Exxon Corp. v. Central Gulf Lines, Inc. case brief summary

Exxon Corp. v. Central Gulf Lines, Inc. (1991)

•                      Unpaid bill for fuels acquired for the vessel Hooper which is owned by CentralGulf chartered by Waterman

•                      Waterman and Exxon negotiated a marine fuel requirements contract - they would fuel them at ports where Exxon was located and when the vessels were at non-Exxon ports, they would arrange for local suppliers to which Exxon would pay and Waterman would pay Exxon

•                      Exxon was Waterman’s agent in getting fuel from Arabian Marine in Saudi Arabia

•                      Arabian Marine billed Exxon, Exxon billed Watrman and Waterman filed Chapter 11 never paying the bill in full

•                      CentralGulf agreed to assume personal liability for the unpaid bill if a court were to hold Hooper liable in rem for that cost

•                      Issue: Whether admiralty jurisdiction extends to claims arising from agency contracts

•                      Minturn v. Maynard - an agent who advanced funds for repairs and supplies necessary for a vessel could not bring a claim in admiralty against the vessel’s owners - should this be overruled?

•                      Holding:           Minturn is overruled there is no per se exception of agency contracts for admiralty jurisdiction

•                      The true criterion in determining whether a contract falls within admiralty is the nature and subject matter of the K, as whether it was a maritime contract, having reference to maritime service or maritime transactions

•                      Courts should look to the subject matter of the agency contract and determine whether the services performed under the contract are maritime in nature

•                      When the nature and subject matter of 2 transactions are the same as they relate to maritime commerce, if admiralty jurisdiction extends to one, it must extend to the other