Lonsdale v. Chesterfield
Supreme Court of Washington, En Banc
662 P.2d 385 (1983)
Chesterfield Land (defendant) sold development plots via real estate contracts requiring it to install a water system, then sold some of its vendor's interests, including deeds for security, to investors like Lonsdale (plaintiff); after the developer's death, his successor Sansaria (defendant) contractually assumed Chesterfield's obligation to install the water systems, including for the already-sold plots, but neither Chesterfield nor Sansaria ever completed the installation, causing purchaser defaults that made the investors' interests worthless. The trial court held Lonsdale and the other investors were not third-party beneficiaries of the Chesterfield-Sansaria contract and dismissed their claim against Sansaria.
Whether the creation of a third party beneficiary contract requires that the contracting parties intend that the promisor assume a direct obligation to the intended beneficiary at the time they enter into the contract.