## Facts

- Central Gulf Lines owned a vessel that was chartered to Waterman Steamship Corporation.
- Exxon and Waterman entered a marine fuel requirements contract under which Exxon would supply fuel directly when possible and, when not, would arrange for local suppliers to deliver fuel and then invoice Waterman.
- At Jeddah, Saudi Arabia, Exxon could not supply fuel directly and procured bunkers from a local supplier for the vessel, paid the supplier, and invoiced Waterman.
- Waterman filed for Chapter 11 bankruptcy and did not pay the full Jeddah fuel invoice.
- Central Gulf agreed in the bankruptcy proceedings to assume personal liability for the bill if a court held the vessel liable in rem.
- Exxon sued Central Gulf in personam and the vessel in rem, asserting a maritime lien under the Federal Maritime Lien Act for the unpaid Jeddah bunkers; Exxon also pursued payment for a separate, unpaid New York fuel delivery that Exxon supplied directly.

## Issues

1. Whether a contract in which a party acts as an agent to procure fuel from a third-party supplier for a specific vessel is a maritime contract within federal admiralty jurisdiction.
2. Whether “agency contracts” are categorically excluded from admiralty jurisdiction under Minturn v. Maynard.
3. Whether the district court had admiralty jurisdiction to entertain Exxon’s in rem lien claim arising from the Jeddah fuel procurement transaction.

## Decision

- The Supreme Court unanimously reversed the Second Circuit and remanded.
- The Court held there is no per se rule excluding agency contracts from admiralty jurisdiction and overruled Minturn v. Maynard to the extent it was read to impose such a categorical bar.
- Applying the modern admiralty test, the Court held the Exxon–Waterman arrangement to procure fuel for a vessel was maritime in nature and therefore within admiralty jurisdiction, leaving remaining statutory and factual matters for resolution on remand.

## Legal Principles

- Admiralty contract jurisdiction depends on the contract’s nature and subject matter, not on formal labels such as “agency.”
- A contract for services maritime in nature—such as procuring necessaries (including bunkers) for a particular vessel—may fall within admiralty jurisdiction.
- Minturn v. Maynard is overruled insofar as it was understood to categorically exclude agency contracts from admiralty jurisdiction.
- The existence of admiralty jurisdiction over a contract does not turn on outdated common-law forms of action or a requirement that the claimant possess a lien interest at the outset.
- Recognizing admiralty jurisdiction over modern intermediary procurement arrangements serves the federal interest in uniform rules and remedies protecting maritime commerce.

## Conclusion

The Court held that agency status does not remove a contract from admiralty jurisdiction; because Exxon’s agreement to procure fuel for the vessel concerned a maritime service, federal admiralty jurisdiction existed over the Jeddah claim, and the case was remanded for further proceedings on the lien and related issues.


Exxon Corp. v. Central Gulf Lines, Inc., 500 U.S. 603 (1991)