Sunday, May 18, 2014

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
 

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