Seaver v. Ransom
Citation and Court
Seaver v. Ransom, 224 N.Y. 233 (N.Y. 1918)
Facts
Judge Beman’s wife was dying. She wanted to leave her house to her niece (Seaver) but agreed to sign a will leaving the house to her husband upon his promise that he would leave Seaver the value of the house in his own will. Judge Beman signed the contract promising to leave the equivalent amount to Seaver, but he died without doing so. Seaver sued the estate as a third-party beneficiary of her aunt’s contract with Beman.
Issue
Whether a party who was promised a benefit under a contract between two other parties—her aunt and uncle—may enforce that promise as a third-party beneficiary.
Holding
The New York Court of Appeals held that Seaver could enforce the promise as a third-party beneficiary because the contract was made for her direct and intended benefit, even though she was not a party to it.
Rule / Doctrine
A third party may sue to enforce a contract made for her benefit when she is an intended beneficiary—one whom the contracting parties directly intended to benefit, as distinct from a mere incidental beneficiary. Family members or other identified donee beneficiaries fall within this category.
Significance
A landmark New York case expanding third-party beneficiary rights to donee beneficiaries in the family context. Establishes the donee beneficiary category alongside creditor beneficiaries and provides the doctrinal foundation for third-party enforcement rights in New York. Pairs with H.R. Moch Co. v. Rensselaer Water Co. to define the limits of the doctrine.