Tredrea v. Anesthesia & Analgesia, P.C.
Supreme Court of Iowa
584 N.W.2d 276 (1998)
Genesis (hospital) contracted with A & A (defendant) for exclusive anesthesiology services, with the contract permitting Genesis to hire remaining staff anesthesiologists as independent contractors so long as agreements were reached by a January 31, 1995 deadline (extendable only with A & A's non-unreasonably-withheld consent); after Genesis's initial offers were refused and the deadline extended twice with A & A's consent, doctors Tredrea and Wells (plaintiffs) accepted a third extension A & A refused to approve, and they sued as third-party beneficiaries, with a jury awarding them over $300,000 each.
Whether a contract can have a third-party beneficiary only if the contract manifests an intent to benefit a third party.