Seaver v. Ransom

Brief Fact Summary. The Plaintiff, Marion Seaver (Plaintiff), sued the Defendants, Matt Ransom and another (Defendants), as executors of the estate of Samuel Beman (Beman), to enforce a contract made between Judge Beman and his late wife, Mrs. Beman, for the benefit of the Plaintiff.

Synopsis of Rule of Law. Any third person, for whose direct benefit a contract was intended, can sue on it.

Facts. Mrs. Beman was near death and had her husband, Judge Beman, draft a will that, among other things, provided that Judge Beman would receive her house for life with the remainder to the American Society for the Prevention of Cruelty to Animals.  Before her death, Mrs. Beman changed her mind and instead wanted the house to go to the Plaintiff, a niece, after her husband’s death.  Mrs. Beman was too weak to wait for the preparation of another will and signed the one already drafted upon the promise from Judge Beman that he would leave the Plaintiff enough in his will to make up the difference.  Upon his death, it was discovered that Judge Beman did not change his will for the benefit of the Plaintiff.  The Plaintiff subsequently initiated this suit to enforce the promise made by Judge Beman to his wife.

Issue. Can the Plaintiff enforce the contract made for her benefit?

Held. Yes.  Equitable principles require that the contract be enforced against the estate.  The contract made between Mrs. Beman and Judge Beman for the Plaintiff to receive the house upon the Judge Beman's death binds the estate to perform on that promise.  This complies with the general doctrine that any third person, for whose direct benefit a contract was intended, could sue on it.  Therefore, the Plaintiff may enforce the contract made for her benefit.

Discussion. A third party beneficiary may recover on a contract made for her benefit.