21 Virginia opinions name it 8 courts 1976–2025 3 in the last five years
The cases below were cited by Virginia courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
Collins v. First Union Nat. Bankgreen2 sentences2023A demurrer does not, however, admit the correctness of the pleader’s conclusions of law.”). -3- 282, 285 (1995))); Collins v. First Union Nat’l Bank, 272 Va. 744, 751 (2006) (“We have consistently held that this third-party beneficiary doctrine is subject to the limitation that the third party must show that the contracting parties clearly and definitely intended that the contract confer a benefit upon him.”); Copenhaver v. Rogers, 238 Va. 361, 367 (1989) (“The essence of a third-party beneficiary’s claim is that others have agreed between themselves to bestow a benefit upon the third party bu 2023A demurrer does not, however, admit the correctness of the pleader’s conclusions of law.”). -3- 282, 285 (1995))); Collins v. First Union Nat’l Bank, 272 Va. 744, 751 (2006) (“We have consistently held that this third-party beneficiary doctrine is subject to the limitation that the third party must show that the contracting parties clearly and definitely intended that the contract confer a benefit upon him.”); Copenhaver v. Rogers, 238 Va. 361, 367 (1989) (“The essence of a third-party beneficiary’s claim is that others have agreed between themselves to bestow a benefit upon the third party bu | 4 | 5 |
Professional Realty Corp. v. Bendergreen2 sentences2025Relatedly, the subcontract provides at § 152.222-700 that the “Contractor . . . shall comply with all applicable . . . regulations and [redacted] policies and practices with respect to equal 9 “The third party beneficiary doctrine is subject to the limitation that the third party must show that the parties to the contract clearly and definitely intended it to confer a benefit upon him.” Prof’l Realty Corp. v. Bender, 216 Va. 737, 739 (1976); see also Tingler v. Graystone Homes, Inc., 298 Va. 63 , 104-05 (2019) (“‘An incidental beneficiary is so far removed from the obligations assumed by the c 1977“The third party beneficiary doctrine is subject to the limitation that the third party must show that the parties to the contract clearly and definitely intended it to confer a benefit upon him .. ..” Professional Realty v. Bender, 216 Va. 737, 739 , 222 S.E.2d 810, 812 (1976). *260 “ ‘A clear intent to benefit the third person must appear to enable him to sue on the contract; incidental beneficiaries cannot maintain an action thereon.’ ” N. -P Newspapers v. Stott, 208 Va. 228, 231 , 156 S.E.2d 610, 612 (1967). | 4 | 4 |
Copenhaver v. Rogersgreen2 sentences2023A demurrer does not, however, admit the correctness of the pleader’s conclusions of law.”). -3- 282, 285 (1995))); Collins v. First Union Nat’l Bank, 272 Va. 744, 751 (2006) (“We have consistently held that this third-party beneficiary doctrine is subject to the limitation that the third party must show that the contracting parties clearly and definitely intended that the contract confer a benefit upon him.”); Copenhaver v. Rogers, 238 Va. 361, 367 (1989) (“The essence of a third-party beneficiary’s claim is that others have agreed between themselves to bestow a benefit upon the third party bu 2023A demurrer does not, however, admit the correctness of the pleader’s conclusions of law.”). -3- 282, 285 (1995))); Collins v. First Union Nat’l Bank, 272 Va. 744, 751 (2006) (“We have consistently held that this third-party beneficiary doctrine is subject to the limitation that the third party must show that the contracting parties clearly and definitely intended that the contract confer a benefit upon him.”); Copenhaver v. Rogers, 238 Va. 361, 367 (1989) (“The essence of a third-party beneficiary’s claim is that others have agreed between themselves to bestow a benefit upon the third party bu | 3 | 7 |
Valley Landscape Co. v. Rollandgreen2 sentences2016A third-party beneficiary rule "has no application unless the party sought to be held liable has assumed an obligation for the benefit of the third party." Valley Landscape Co. , 218 Va. at 259 -60 , 237 S.E.2d at 122 . 2016A third-party beneficiary rule "has no application unless the party sought to be held liable has assumed an obligation for the benefit of the third party." Valley Landscape Co. , 218 Va. at 259 -60 , 237 S.E.2d at 122 . | 2 | 4 |
MNC Credit Corp. v. Sickelsgreen2 sentences2023A demurrer does not, however, admit the correctness of the pleader’s conclusions of law.”). -3- 282, 285 (1995))); Collins v. First Union Nat’l Bank, 272 Va. 744, 751 (2006) (“We have consistently held that this third-party beneficiary doctrine is subject to the limitation that the third party must show that the contracting parties clearly and definitely intended that the contract confer a benefit upon him.”); Copenhaver v. Rogers, 238 Va. 361, 367 (1989) (“The essence of a third-party beneficiary’s claim is that others have agreed between themselves to bestow a benefit upon the third party bu 2023A demurrer does not, however, admit the correctness of the pleader’s conclusions of law.”). -3- 282, 285 (1995))); Collins v. First Union Nat’l Bank, 272 Va. 744, 751 (2006) (“We have consistently held that this third-party beneficiary doctrine is subject to the limitation that the third party must show that the contracting parties clearly and definitely intended that the contract confer a benefit upon him.”); Copenhaver v. Rogers, 238 Va. 361, 367 (1989) (“The essence of a third-party beneficiary’s claim is that others have agreed between themselves to bestow a benefit upon the third party bu | 2 | 3 |
Thorsen v. Richmond Soc'y for the Prevention of Cruelty to Animalsgreen2 sentences2025Relatedly, the subcontract provides at § 152.222-700 that the “Contractor . . . shall comply with all applicable . . . regulations and [redacted] policies and practices with respect to equal 9 “The third party beneficiary doctrine is subject to the limitation that the third party must show that the parties to the contract clearly and definitely intended it to confer a benefit upon him.” Prof’l Realty Corp. v. Bender, 216 Va. 737, 739 (1976); see also Tingler v. Graystone Homes, Inc., 298 Va. 63 , 104-05 (2019) (“‘An incidental beneficiary is so far removed from the obligations assumed by the c 2019“An incidental beneficiary is so far removed from the obligations assumed by the contracting parties that a court will not allow him to sue on that contract,” but “an intended beneficiary is such an integral part of the obligations assumed by the contracting parties that a court will permit him to sue on that contract.” Thorsen v. Richmond Soc’y for the Prevention of Cruelty to Animals, 292 Va. 257, 273 (2016). | 2 | 2 |
Ogunde v. Prison Health Services, Inc.green2 sentences2023See Code § 55.1-119; see also Ogunde v. Prison Health Servs., Inc., 274 Va. 55, 63 (2007) (“[U]nder certain circumstances, a party may sue to enforce the terms of a contract even though he is not a party to the contract.” (quoting Levine v. Selective Ins. 2023See Code § 55.1-119; see also Ogunde v. Prison Health Servs., Inc., 274 Va. 55, 63 (2007) (“[U]nder certain circumstances, a party may sue to enforce the terms of a contract even though he is not a party to the contract.” (quoting Levine v. Selective Ins. | 2 | 2 |
Norfolk-Portsmouth Newspapers, Inc. v. Stottgreen2 sentences1977“The third party beneficiary doctrine is subject to the limitation that the third party must show that the parties to the contract clearly and definitely intended it to confer a benefit upon him .. ..” Professional Realty v. Bender, 216 Va. 737, 739 , 222 S.E.2d 810, 812 (1976). *260 “ ‘A clear intent to benefit the third person must appear to enable him to sue on the contract; incidental beneficiaries cannot maintain an action thereon.’ ” N. -P Newspapers v. Stott, 208 Va. 228, 231 , 156 S.E.2d 610, 612 (1967). 1977“The third party beneficiary doctrine is subject to the limitation that the third party must show that the parties to the contract clearly and definitely intended it to confer a benefit upon him .. ..” Professional Realty v. Bender, 216 Va. 737, 739 , 222 S.E.2d 810, 812 (1976). *260 “ ‘A clear intent to benefit the third person must appear to enable him to sue on the contract; incidental beneficiaries cannot maintain an action thereon.’ ” N. -P Newspapers v. Stott, 208 Va. 228, 231 , 156 S.E.2d 610, 612 (1967). | 2 | 2 |
Forbes v. Schaefergreen2 sentences2006Caudill v. County of Dinwiddie, 259 Va. 785 , 793, 529 S.E.2d 313 , 317 (2000); MNC Credit Corp. v. Sickels, 255 Va. 314 , 320, 497 S.E.2d 331 , 334 (1998); Forbes v. Schaefer, 226 Va. 391 , 401, 310 S.E.2d 457 , 463 (1983). 2006Caudill v. County of Dinwiddie, 259 Va. 785 , 793, 529 S.E.2d 313 , 317 (2000); MNC Credit Corp. v. Sickels, 255 Va. 314 , 320, 497 S.E.2d 331 , 334 (1998); Forbes v. Schaefer, 226 Va. 391 , 401, 310 S.E.2d 457 , 463 (1983). | 1 | 2 |
Kelley v. Griffingreen1 sentence2025Relatedly, the subcontract provides at § 152.222-700 that the “Contractor . . . shall comply with all applicable . . . regulations and [redacted] policies and practices with respect to equal 9 “The third party beneficiary doctrine is subject to the limitation that the third party must show that the parties to the contract clearly and definitely intended it to confer a benefit upon him.” Prof’l Realty Corp. v. Bender, 216 Va. 737, 739 (1976); see also Tingler v. Graystone Homes, Inc., 298 Va. 63 , 104-05 (2019) (“‘An incidental beneficiary is so far removed from the obligations assumed by the c | 1 | 1 |
Gaines v. American Title Insurancegreen1 sentence1991See, Gaines v. American Title Insurance Company, 220 S.E.2d 469 (Ga. App. 1975); Sherrill v. Louisville Title Insurance Company, 214 S.E.2d 410 (Ga. App. 1985); Hooper v. Commonwealth Land Title Insurance Company, 427 A.2d 215 (Pa. Super. 1981). | 1 | 1 |
W. D. Nelson & Co. v. Taylor Heights Development Corp.green2 sentences1979But the third party must clearly show that the contracting parties definitely intended the contract to confer a benefit upon him, Valley Company v. Rolland, 218 Va. 257, 259 , 237 S.E.2d 120, 122 (1977); Nelson & Co. v. Taylor Heights Development Corp., 207 Va. 386, 390-91 , 150 S.E.2d 142, 146 (1966); incidental beneficiaries may not sue thereon. 1979But the third party must clearly show that the contracting parties definitely intended the contract to confer a benefit upon him, Valley Company v. Rolland, 218 Va. 257, 259 , 237 S.E.2d 120, 122 (1977); Nelson & Co. v. Taylor Heights Development Corp., 207 Va. 386, 390-91 , 150 S.E.2d 142, 146 (1966); incidental beneficiaries may not sue thereon. | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Virginia. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Envtl. Staffing v. B & R Const. Mgmt.
green
2 sentences2013The Supreme Court of Virginia has “recognized a specific limitation to the third-party beneficiary doctrine in that ‘the third party must show that the contracting parties clearly and definitely intended that the contract confer a benefit on him’.” Environmental Staffing Corp. v. B & R Construction Management, 283 Va. 787, 793 , 725 S.E.2d 550 (2012). 2013The Supreme Court of Virginia has “recognized a specific limitation to the third-party beneficiary doctrine in that ‘the third party must show that the contracting parties clearly and definitely intended that the contract confer a benefit on him’.” Environmental Staffing Corp. v. B & R Construction Management, 283 Va. 787, 793 , 725 S.E.2d 550 (2012). | 2 | 2013–2013 |
Ward v. Ernst & Young
green
2 sentences2016Despite the majority's implication otherwise, the Court in Ward v. Ernst & Young, 246 Va. 317 , 435 S.E.2d 628 (1993), made no comparison between accountants and attorneys in its analysis of the third-party beneficiary claim in that case. 2016Despite the majority's implication otherwise, the Court in Ward v. Ernst & Young, 246 Va. 317 , 435 S.E.2d 628 (1993), made no comparison between accountants and attorneys in its analysis of the third-party beneficiary claim in that case. | 1 | 2016–2016 |
Ward's Equipment, Inc. v. New Holland North America, Inc.
green
2 sentences2011It is conceded that there was a written contract between the Employer and Wolfe. “[A] court considering a demurrer may ignore a party’s factual allegations contradicted by the terms of authentic, unambiguous documents that properly are a part of the pleadings.” Ward’s Equip, v. New Holland N. Am., 254 Va. 379, 382 , 493 S.E.2d 516 (1997). 2011It is conceded that there was a written contract between the Employer and Wolfe. “[A] court considering a demurrer may ignore a party’s factual allegations contradicted by the terms of authentic, unambiguous documents that properly are a part of the pleadings.” Ward’s Equip, v. New Holland N. Am., 254 Va. 379, 382 , 493 S.E.2d 516 (1997). | 1 | 2011–2011 |
Caudill v. County of Dinwiddie
green
2 sentences2006Caudill v. County of Dinwiddie, 259 Va. 785 , 793, 529 S.E.2d 313 , 317 (2000); MNC Credit Corp. v. Sickels, 255 Va. 314 , 320, 497 S.E.2d 331 , 334 (1998); Forbes v. Schaefer, 226 Va. 391 , 401, 310 S.E.2d 457 , 463 (1983). 2006Caudill v. County of Dinwiddie, 259 Va. 785 , 793, 529 S.E.2d 313 , 317 (2000); MNC Credit Corp. v. Sickels, 255 Va. 314 , 320, 497 S.E.2d 331 , 334 (1998); Forbes v. Schaefer, 226 Va. 391 , 401, 310 S.E.2d 457 , 463 (1983). | 1 | 2006–2006 |
Levine v. Selective Insurance Co. of America
green
1 sentence1999Id. at 286 . | 1 | 1999–1999 |
Richmond Shopping Center, Inc. v. Wiley N. Jackson Co.
green
2 sentences1996In Richmond Center v. Jackson Co., 220 Va. 135 , 255 S.E.2d 518 (1979), the court decided that the contract at issue in the third party beneficiary claim was clear and that evidence outside the four comers of the contract would not be considered. 1996In Richmond Center v. Jackson Co., 220 Va. 135 , 255 S.E.2d 518 (1979), the court decided that the contract at issue in the third party beneficiary claim was clear and that evidence outside the four comers of the contract would not be considered. | 1 | 1996–1996 |
Hooper v. Commonwealth Land Title Insurance
green
1 sentence1991See, Gaines v. American Title Insurance Company, 220 S.E.2d 469 (Ga. App. 1975); Sherrill v. Louisville Title Insurance Company, 214 S.E.2d 410 (Ga. App. 1985); Hooper v. Commonwealth Land Title Insurance Company, 427 A.2d 215 (Pa. Super. 1981). | 1 | 1991–1991 |
Sherrill v. Louisville Title Insurance
green
1 sentence1991See, Gaines v. American Title Insurance Company, 220 S.E.2d 469 (Ga. App. 1975); Sherrill v. Louisville Title Insurance Company, 214 S.E.2d 410 (Ga. App. 1985); Hooper v. Commonwealth Land Title Insurance Company, 427 A.2d 215 (Pa. Super. 1981). | 1 | 1991–1991 |
Stowe v. Smith
green
2 sentences1989The Copenhavers never alleged that their grandparents and Rogers entered a contract of which they were intended beneficiaries. 2 Thus, the motion for judgment utterly fails to allege a third-party beneficiary contract claim. 3 In Stowe v. Smith, 184 Conn. 194 , 441 A.2d 81 (1981), a case relied on by the Copenhavers, a motion to strike a complaint was originally granted with regard to a third-party beneficiary claim against a lawyer who had allegedly failed to prepare a will pursuant to his client’s instructions. 1989The Copenhavers never alleged that their grandparents and Rogers entered a contract of which they were intended beneficiaries. 2 Thus, the motion for judgment utterly fails to allege a third-party beneficiary contract claim. 3 In Stowe v. Smith, 184 Conn. 194 , 441 A.2d 81 (1981), a case relied on by the Copenhavers, a motion to strike a complaint was originally granted with regard to a third-party beneficiary claim against a lawyer who had allegedly failed to prepare a will pursuant to his client’s instructions. | 1 | 1989–1989 |
SPIRES Et Ux. v. Hanover Fire Ins. Co.
green
2 sentences1989In Guy , the court concluded that under previously existing Pennsylvania law as set forth in Spires v. Hanover Fire Insurance Co., 364 Pa. 52 , 70 A.2d 828 (1950), a third-party beneficiary claim could not be successfully asserted: Under the Spires analysis, a beneficiary of a will would be a third party beneficiary with standing only if the testator and the attorney had a written contract to write a will, and the contract indicated the intention of both parties to benefit the legatee. 1989In Guy , the court concluded that under previously existing Pennsylvania law as set forth in Spires v. Hanover Fire Insurance Co., 364 Pa. 52 , 70 A.2d 828 (1950), a third-party beneficiary claim could not be successfully asserted: Under the Spires analysis, a beneficiary of a will would be a third party beneficiary with standing only if the testator and the attorney had a written contract to write a will, and the contract indicated the intention of both parties to benefit the legatee. | 1 | 1989–1989 |
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.
Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.