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Services or Employment Contracts

A contract under which a domestic corporation agreed to solicit sailing trainees for a voyage on a foreign citizen’s vessel falls within admiralty jurisdiction.[i]  However, an agreement to offer reliable information concerning smuggling operations in exchange for compensation is not a maritime agreement, even though the subject of the agreement involved the use of a private vessel in customs operation.[ii]  A claim for unpaid wages based on an agreement for payment as a proportionate share of fish caught is a maritime contract within admiralty jurisdiction.[iii]  When the employee has duties that involve rescue vessel operation, a contract of employment with a county as a lifeguard and rescue boat lieutenant is maritime in nature.[iv]

[i] American Sail Training Ass’n v. Litchfield, 705 F. Supp. 75 (D.R.I. 1989).

[ii] Cesaroni v. U.S., 624 F. Supp. 613 (S.D. Ga. 1985), judgment aff’d, 780 F.2d 1031 (11th Cir. 1985).

[iii] Cummings v. Miller Time, 705 F. Supp. 62 (D.P.R. 1988)

[iv] Hamilton v. County of Los Angeles, 131 Cal. App. 3d 982, 182 Cal. Rptr. 868 (2d Dist. 1982).

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