For centuries courts have faced theoretical, doctrinal, and practical difficulties in determining whether a third person may enforce a contract made by others for his benefit. Attempts by courts and scholars to formulate tests for determining third party rights have in most instances created as many problems as they have solved. The decision of the California Supreme Court in Martinez v. Socoma Companies not only exemplifies the myriad problems encountered by courts in determining third party beneficiary rights but also pointedly demonstrates the need for more workable decisionmaking criteria in this area of contract law.
Kay S. Bruce,
Martinez v. Socoma Companies: Problems in Determining Contract Beneficiaries' Rights,
27 Hastings L.J. 137
Available at: https://repository.uchastings.edu/hastings_law_journal/vol27/iss1/4