third-party beneficiary exception (Alabama) · Go Syfert
← Alabama issues

third-party beneficiary exception in Alabama

8 Alabama opinions name it 2 courts 1975–2017 0 in the last five years

The cases below were cited by Alabama 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.

Followed or applied (7)

CaseFollowedCited
Cook's Pest Control, Inc. v. Boykingreen
ala · 2001 · cited in 3 Alabama opinions naming this issue, 2003–2017
2 sentences

2017See Jack Ingram Motors, Inc. v. Ward , 768 So.2d 362 (Ala. 1999) (holding that an arbitration provision that limited its scope to the buyer/lessor and dealer was not broad enough to cover a nonsignatory); see also Cook's Pest Control, Inc. v. Boykin , 807 So.2d 524 , 527 (Ala. 2001), explaining: "The narrow scope of the arbitration agreement serves as an independent basis for affirming the trial court's order denying Cook's motion to compel arbitration of Allen's claims against Cook's.

2003See Credit Sales, Inc. v. Crimm, supra; Cook's Pest Control, Inc. v. Boykin, supra; Georgia Power Co. v. Partin, supra; Ex parte Dyess, supra. Therefore, we agree with Hill that it has not been demonstrated that he is subject to the third-party-beneficiary exception that would require him, as a nonsignatory to the listing agreement, to arbitrate his claims against NAG pursuant to the arbitration provision contained in the listing agreement.

13
Jack Ingram Motors, Inc. v. Wardgreen
ala · 1999 · cited in 1 Alabama opinions naming this issue, 2017–2017
1 sentence

2017See Jack Ingram Motors, Inc. v. Ward , 768 So.2d 362 (Ala. 1999) (holding that an arbitration provision that limited its scope to the buyer/lessor and dealer was not broad enough to cover a nonsignatory); see also Cook's Pest Control, Inc. v. Boykin , 807 So.2d 524 , 527 (Ala. 2001), explaining: "The narrow scope of the arbitration agreement serves as an independent basis for affirming the trial court's order denying Cook's motion to compel arbitration of Allen's claims against Cook's.

11
Edwards v. Costnergreen
ala · 2007 · cited in 1 Alabama opinions naming this issue, 2010–2010
1 sentence

2010See Edwards v. Costner, 979 So.2d 757, 763-64 (Ala.2007) (“Edwards and Edwards Motors did not argue to the trial court or to this Court that Costner was an intended third-party beneficiary at the time the arbitration agreement was signed, nor is there evidence in the record indicating that that is the case.

11
Bay Lines, Inc. v. Stoughton Trailers, Inc.green
ala · 2002 · cited in 1 Alabama opinions naming this issue, 2006–2006
1 sentence

2006Bay Lines, therefore, cannot rely on the warranty to support its [third-party-beneficiary] claim against Crane." 838 So.2d at 1018-19 (emphasis added).

11
Stamey v. Eastergreen
ala · 2000 · cited in 1 Alabama opinions naming this issue, 2003–2003
1 sentence

2003Our supreme court has stated that a party who claims to be a third-party beneficiary of a contract must demonstrate that the parties to the contract intended "`to bestow a direct, as opposed to an incidental, benefit upon the third party.'" Ex parte Stamey, 776 So.2d 85, 92 (Ala.2000) (quoting Weathers Auto Glass, Inc. v. Alfa Mut.

11
Credit Sales, Inc. v. Crimmgreen
ala · 2001 · cited in 1 Alabama opinions naming this issue, 2003–2003
1 sentence

2003See Credit Sales, Inc. v. Crimm, supra; Cook's Pest Control, Inc. v. Boykin, supra; Georgia Power Co. v. Partin, supra; Ex parte Dyess, supra. Therefore, we agree with Hill that it has not been demonstrated that he is subject to the third-party-beneficiary exception that would require him, as a nonsignatory to the listing agreement, to arbitrate his claims against NAG pursuant to the arbitration provision contained in the listing agreement.

11
AmSouth Bank v. Deesgreen
ala · 2002 · cited in 1 Alabama opinions naming this issue, 2003–2003
1 sentence

2003See AmSouth Bank v. Dees, 847 So.2d 923 (Ala.2002); SouthTrust Bank v. Ford, 835 So.2d 990 (Ala.2002); Conseco Fin.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Alabama. Read the followed side critically anyway.

Also cited on this issue (12)

CaseCitedYears
Georgia Power Co. v. Partin green
ala · 1998
2 sentences

2007In Georgia Power Co. v. Partin , 727 So.2d 2 (Ala. 1998), the Alabama Supreme Court repeated the rule that a third-party beneficiary may not claim the benefits of a contract without being bound by the limitations of the contract: "It is a well-established principle of Alabama law that a contract made for the benefit of a third person may, at his election, be accepted and enforced by him.

2003See Credit Sales, Inc. v. Crimm, supra; Cook's Pest Control, Inc. v. Boykin, supra; Georgia Power Co. v. Partin, supra; Ex parte Dyess, supra. Therefore, we agree with Hill that it has not been demonstrated that he is subject to the third-party-beneficiary exception that would require him, as a nonsignatory to the listing agreement, to arbitrate his claims against NAG pursuant to the arbitration provision contained in the listing agreement.

22003–2007
MTA, Inc. v. Merrill Lynch, Pierce, Fenner & Smith, Inc. green
ala · 2012
1 sentence

2016Dannelly, relying upon MTA, Inc. v. Merrill Lynch, Pierce, Fenner & Smith, Inc., 114 So.3d 27 (Ala.2012), argues that, regardless of whether the third-party-beneficiary exception applies in this case, the arbitration provision in the master subcontract agreement is too narrow to encompass PBG’s third-party claims against Dannelly.

12016–2016
Fountain v. Ingram green
ala · 2005
1 sentence

2010Equitable Estoppel Arbitration may be compelled “ ‘under the doctrine of “intertwining,” where arbitrable and nonarbitrable claims are so closely related that the party to a controversy subject to arbitration is equitably estopped to deny the arbitrability of the related claim.’ ” Fountain, 926 So.2d at 335 (quoting Conseco Fin.

12010–2010
Michie v. Bradshaw green
· 1933
2 sentences

2007Michie v. Bradshaw , 227 Ala. 302 , 149 So. 809 (1933).

2007Michie v. Bradshaw , 227 Ala. 302 , 149 So. 809 (1933).

12007–2007
Palm Harbor Homes, Inc. v. Crawford green
ala · 1997
1 sentence

2006Palm Harbor Homes, Inc. v. Crawford, 689 So.2d 3 (Ala.1997).

12006–2006
SouthTrust Bank v. Ford green
ala · 2002
1 sentence

2003See AmSouth Bank v. Dees, 847 So.2d 923 (Ala.2002); SouthTrust Bank v. Ford, 835 So.2d 990 (Ala.2002); Conseco Fin.

12003–2003
Stacey v. Saunders green
ala · 1983
2 sentences

2003Stacey v. Saunders, 437 So.2d 1230 (Ala.1983) (plaintiffs were not third-party beneficiaries of an antenuptial agreement entered into by their mother and her intended husband with respect to a trust designed to pay the wife income for her life and give her "`a power to appoint by will to her estate, or to such persons as she may elect, the entire corpus and any undistributed income of the trust.'" 437 So.2d at 1232 .

2003Stacey v. Saunders, 437 So.2d 1230 (Ala.1983) (plaintiffs were not third-party beneficiaries of an antenuptial agreement entered into by their mother and her intended husband with respect to a trust designed to pay the wife income for her life and give her "`a power to appoint by will to her estate, or to such persons as she may elect, the entire corpus and any undistributed income of the trust.'" 437 So.2d at 1232 .

12003–2003
Ex Parte Dyess green
ala · 1997
1 sentence

2003See Credit Sales, Inc. v. Crimm, supra; Cook's Pest Control, Inc. v. Boykin, supra; Georgia Power Co. v. Partin, supra; Ex parte Dyess, supra. Therefore, we agree with Hill that it has not been demonstrated that he is subject to the third-party-beneficiary exception that would require him, as a nonsignatory to the listing agreement, to arbitrate his claims against NAG pursuant to the arbitration provision contained in the listing agreement.

12003–2003
Royal Indemnity Co. v. City of Erie green
pawd · 1971
2 sentences

1975Royal Indemnity Co. v. City of Erie, 326 F.Supp. 571 (W.D.Pa.1971); Doyle v. South Pittsburgh Water Company, 414 Pa. 199 , 199 A.2d 875 (1964); Potter v. Carolina Water Company, 253 N.C. 112 , 116 S. E.2d 374 (1960); Pineville Water Company v. Bradshaw, 266 S.W.2d 305 (Ky. 1953).

1975Royal Indemnity Co. v. City of Erie, 326 F.Supp. 571 (W.D.Pa.1971); Doyle v. South Pittsburgh Water Company, 414 Pa. 199 , 199 A.2d 875 (1964); Potter v. Carolina Water Company, 253 N.C. 112 , 116 S.E.2d 374 (1960) ; Pineville Water Company v. Bradshaw, 266 S.W.2d 305 (Ky.1953).

11975–1975
Pineville Water Co. v. Bradshaw neutral
kyctapp · 1953
2 sentences

1975Royal Indemnity Co. v. City of Erie, 326 F.Supp. 571 (W.D.Pa.1971); Doyle v. South Pittsburgh Water Company, 414 Pa. 199 , 199 A.2d 875 (1964); Potter v. Carolina Water Company, 253 N.C. 112 , 116 S. E.2d 374 (1960); Pineville Water Company v. Bradshaw, 266 S.W.2d 305 (Ky. 1953).

1975Royal Indemnity Co. v. City of Erie, 326 F.Supp. 571 (W.D.Pa.1971); Doyle v. South Pittsburgh Water Company, 414 Pa. 199 , 199 A.2d 875 (1964); Potter v. Carolina Water Company, 253 N.C. 112 , 116 S.E.2d 374 (1960) ; Pineville Water Company v. Bradshaw, 266 S.W.2d 305 (Ky.1953).

11975–1975
Doyle v. South Pittsburgh Water Co. green
pa · 1964
2 sentences

1975Royal Indemnity Co. v. City of Erie, 326 F.Supp. 571 (W.D.Pa.1971); Doyle v. South Pittsburgh Water Company, 414 Pa. 199 , 199 A.2d 875 (1964); Potter v. Carolina Water Company, 253 N.C. 112 , 116 S.E.2d 374 (1960) ; Pineville Water Company v. Bradshaw, 266 S.W.2d 305 (Ky.1953).

1975Royal Indemnity Co. v. City of Erie, 326 F.Supp. 571 (W.D.Pa.1971); Doyle v. South Pittsburgh Water Company, 414 Pa. 199 , 199 A.2d 875 (1964); Potter v. Carolina Water Company, 253 N.C. 112 , 116 S.E.2d 374 (1960) ; Pineville Water Company v. Bradshaw, 266 S.W.2d 305 (Ky.1953).

11975–1975
Potter v. Carolina Water Company green
nc · 1960
2 sentences

1975Royal Indemnity Co. v. City of Erie, 326 F.Supp. 571 (W.D.Pa.1971); Doyle v. South Pittsburgh Water Company, 414 Pa. 199 , 199 A.2d 875 (1964); Potter v. Carolina Water Company, 253 N.C. 112 , 116 S.E.2d 374 (1960) ; Pineville Water Company v. Bradshaw, 266 S.W.2d 305 (Ky.1953).

1975Royal Indemnity Co. v. City of Erie, 326 F.Supp. 571 (W.D.Pa.1971); Doyle v. South Pittsburgh Water Company, 414 Pa. 199 , 199 A.2d 875 (1964); Potter v. Carolina Water Company, 253 N.C. 112 , 116 S.E.2d 374 (1960) ; Pineville Water Company v. Bradshaw, 266 S.W.2d 305 (Ky.1953).

11975–1975

Where else courts name it

CA 40 (1986–2025) TX 37 (1988–2021) NY 30 (1957–2025) IL 23 (1965–2022) VA 21 (1976–2025) FL 20 (1969–2022) MD 16 (1977–2024) IA 13 (2006–2025) NC 12 (1962–2026) AR 11 (1992–2025) GA 9 (1964–2020) AZ 9 (1971–2025) AL 8 (1975–2017) OH 8 (1990–2025) MI 8 (1936–2020) WA 8 (1965–2003) WI 7 (1969–2025) PA 7 (1938–2020) NM 6 (2001–2025) CT 6 (1938–2001) DC 5 (1965–2018) ME 5 (2014–2018) CO 5 (1988–2006) UT 4 (1996–2023) HI 4 (2001–2013) SC 4 (1984–2024) MA 4 (1976–2014) TN 3 (2008–2022) NH 3 (1983–2012) NJ 3 (1988–2022) WY 3 (1991–2004) OR 2 (1965–2008) IN 2 (1998–2004) KS 2 (1992–1995) ID 2 (1993–2004) ND 2 (2024–2024) MO 2 (1991–2009) RI 2 (2015–2019) NV 2 (2022–2026) KY 2 (2007–2026)

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.

← Caselaw search · G Cite Topics · Brief Check