A promise to pay a person for doing that which he is already under contract to do is without consideration.
Libelant fishermen contracted with Appellant company to sail from San Francisco to Alaska and work for appellant during the fishing season. When the ship arrived in Alaska, the fishermen demanded higher wages than were provided for in the contract; the fishermen stated that they would not work unless they were paid additional wages. Compelled by the remote location and difficulty of finding replacement workers, the company agreed. When the fishermen returned to San Francisco, appellant denied the validity of the later contract.
Was the second contract supported by sufficient consideration?
The court held that the later contract was not supported by adequate consideration because the fishermen were already contractually obligated to perform the specified services and therefore the later contract that was merely a demand for more compensation.