The Elfrida

172 U.S. 186, 19 S.Ct. 146, 43 L.Ed. 413, 2002 AMC 2982 (1898)

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The Elfrida

United States Supreme Court
172 U.S. 186, 19 S.Ct. 146, 43 L.Ed. 413, 2002 AMC 2982 (1898)

CS

Facts

The Elfrida ran aground in a channel at the mouth of the Brazos River, floundered over a jetty, and was eventually pushed hundreds of feet from open water into the sand and beached. After failed attempts to free the ship, the Elfrida’s master contacted the ship’s owner and insurer for instructions on obtaining salvage services. Following their advice, the Elfrida’s master contracted with Charles Clarke (plaintiff) to provide salvage services. Under the terms of the contract, Clarke would be paid only if the effort was successful and completed within 21 days. The agreed-upon payment amount was $22,000, about one-quarter of the Elfrida’s value. The contract additionally retained the option for the ship’s owner, Pyman, Bell & Co. (defendant) to surrender the ship itself in lieu of payment if the owner so chose. Clarke and his team managed to successfully free the Elfrida and complete the salvage in just a few days. Clarke brought his salvage claim against Pyman, Bell & Co., and the district court awarded Clarke $22,000 as per the contract. Upon appeal, however, the circuit court of appeals reduced the award to $10,000, and Clarke appealed.

Rule of Law

Issue

Holding and Reasoning (Brown, J.)

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