Astra USA, Inc. v. Santa Clara County
Supreme Court of the United States
131 S. Ct. 1342 (2011)
Federal law capped drug prices manufacturers could charge covered entities like Santa Clara County (plaintiff), enforced only by HHS, with no private right of action; manufacturers opted into this program by signing form Pharmaceutical Pricing Agreements (PPAs) that simply restated their statutory pricing obligations, and the county sued Astra (defendant) and others as an intended third-party beneficiary of those PPAs after being allegedly overcharged.
Whether, if a statute does not allow a third-party beneficiary to bring an action to enforce the statute's obligations, the third-party beneficiary may bring an action to enforce a contract that simply confirms those statutory obligations.