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Spanish-American Trade, privateer, Quasi-War, prize law, agent, principal, maritime trade, merchant, tobacco, contraband


Manella v. Barry highlights issues of agency and contract interpretation in the international maritime trade context. In the midst of America’s entry into the Quasi-War with France, a Baltimore shipping merchant brokered a large tobacco trade with a Spanish firm and experienced the risks of conducting trade over the high seas during wartime. Three out of seven ships were captured, and the Spanish firm sought to recover from the Baltimore merchant for the price of the lost cargo. Both the Circuit Court of Maryland and John Marshall’s Supreme Court sided with James Barry, holding that the Baltimore merchant was not liable for the loss because he followed the instructions of the agent sent to broker the deal.


Agency | Law | Legal History