Martinez v. Socoma Companies, Inc.
Supreme Court of California
521 P.2d 841 (1974)
After Congress created Special Impact programs to aid low-income neighborhoods and the Department of Labor designated East Los Angeles as a Special Impact Area, Socoma Companies and other businesses (defendants) contracted with the government in 1969 to invest $5 million establishing manufacturing facilities and to employ neighborhood residents. Martinez and other qualified residents (plaintiffs) sued when Socoma failed to build the facilities or hire them, but the trial court found they lacked standing as only incidental beneficiaries of the contracts, and they appealed.
Whether individuals who were to be employed under, but were not parties to, a government contract can enforce that contract as third-party beneficiaries.