Exxon Corp. v. Central Gulf Lines, Inc.

Background

Exxon, a longtime fuel supplier, had a contract to supply marine fuel to Waterman’s ships. The Hooper, owned by Central Gulf, called at Jeddah where Exxon acted as Waterman’s agent and bought fuel from Arabian Marine, paid the supplier, and billed Waterman $763,644. Waterman later entered Chapter 11 bankruptcy and did not pay the full bill. Central Gulf agreed to assume liability if a court held the Hooper liable. Exxon sued Central Gulf in personam and the Hooper in rem, claiming a maritime lien under the Federal Maritime Lien Act; lower courts dismissed the agency-based claim under an 1855 rule (Minturn) that some courts read as barring agency contracts from admiralty jurisdiction.

Reasoning

The Court examined whether the Minturn rule still fit modern admiralty law. It found Minturn’s original rationales—treating agent claims as mere account actions and requiring the vessel to be pledged as security—obsolete. The Court emphasized that admiralty jurisdiction should turn on the nature and subject matter of the contract, not on the claimant’s status as an agent. Accordingly, the Court overruled Minturn’s per se exclusion and instructed lower courts to decide admiralty jurisdiction by looking to whether the services performed were maritime in character.

Real world impact

By removing Minturn’s blanket bar, suppliers and agents may bring maritime claims when the contract’s subject matter is maritime. The Court specifically held Exxon’s Jeddah fuel claim was maritime because it involved fuel supplied to a ship, like the undisputed New York delivery. The Court did not decide whether Exxon has a maritime lien and remanded that issue for further proceedings. The ruling is narrow: it removes only Minturn and leaves other doctrines to be applied by lower courts.