Notes - Seaver v. Ransom



1. In his Seaver v. Ransom opinion, Pound, J., suggests that De Cicco v. Schweizer, 221 N.Y. 431, 117 N.E. 807 (1917), had extended the range of New York third party beneficiary doctrine. The De Cicco case is re-printed supra p. 494. Do you read the opinion of Cardozo, J., in De Cicco as saying that Blanche Schweizer could have brought an action as third party beneficiary on the contract between her father and Count Gulinelli?


2. Does it seem to you that Seaver v. Ransom in effect overrules Vrooman v. Turner, supra p. 1346? If so, what test does Seaver establish for determining which classes of beneficiaries are entitled to sue?