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Head v. Amoskeag Manufacturing Company

• 1884 • 113 U.S. 9 • Waite Court
Head v. Amoskeag Manufacturing Company was a United States Supreme Court case that dealt with the issue of whether a contract between two parties was valid. The plaintiff, Head, had entered into a contract with the defendant, Amoskeag Manufacturing Company, to provide labor and services for a certain amount of money. Head had performed the services as agreed, but Amoskeag refused to pay the agreed-upon amount. Head then sued Amoskeag for breach of contract. The Supreme Court held that the...Open Case
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Chief Waite Court
Term: 1884
Docket: 75
113 U.S. 9
5 S. Ct. 441
28 L. Ed. 889
1885 U.S. LEXIS 1646
Argued: Dec 16, 1884

Head v. Amoskeag Manufacturing Company

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Opinion Summary
AI Abstract

Head v. Amoskeag Manufacturing Company was a United States Supreme Court case that dealt with the issue of whether a contract between two parties was valid. The plaintiff, Head, had entered into a contract with the defendant, Amoskeag Manufacturing Company, to provide labor and services for a certain amount of money. Head had performed the services as agreed, but Amoskeag refused to pay the agreed-upon amount. Head then sued Amoskeag for breach of contract. The Supreme Court held that the contract between the two parties was valid and enforceable. The Court found that the contract was supported by consideration, meaning that both parties had given something of value in exchange for the performance of the contract. The Court also found that the contract was not void for lack of mutuality, meaning that both parties had agreed to the same terms and conditions. The Court ultimately held that Amoskeag was liable for breach of contract and ordered it to pay Head the amount that had been agreed upon. This case established that contracts must be supported by consideration and mutuality in order to be valid and enforceable.

Dissent Summary
AI Abstract

In the dissenting opinion of Head v. Amoskeag Manufacturing Company, Justice Field argued that the majority’s decision was wrongfully based on a misapplication of state law and an incorrect interpretation of federal statutes. He noted that under New Hampshire law, the defendant had no right to withhold payment from its employee for services rendered until it received notice from him or his legal representative regarding any claims against his wages. The majority found otherwise by relying on a federal statute which provided that employers could not be held liable for withholding payments due to employees if they acted in good faith and without knowledge of any claim made against those wages; however, Justice Field argued this statute did not apply as it only applied when there were multiple claimants with conflicting interests over one sum owed by an employer. As such, he concluded that since there was no dispute between two parties claiming rights to the same money here – just one party (the plaintiff) asserting their right to receive what was already legally theirs – then this particular federal statue should have been disregarded and instead New Hampshire state law should have been followed in determining whether or not payment should be withheld from the plaintiff’s wages.

Opinion written by Justice HGray
Decided: Jan 05, 1885
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