Friday, December 27, 2013

Martinez v. Socoma Companies, Inc.

Martinez v. Socoma Companies, Inc. case brief summary
521 P.2d 841 (1974)

CASE SYNOPSIS
Plaintiffs appealed a decision of the Superior Court of Los Angeles County (California) which sustained defendants' general demurrers to the complaint in a suit alleging that defendants breached contracts with the United States made pursuant to 1967 amendments to the Economic Opportunity Act of 1964 , 42 U.S.C.S. §§ 2763-2768.

CASE FACTS
Plaintiffs, a class of unemployed persons, sued defendant companies alleging that they breached contracts made with the United States pursuant to the 1967 amendments to the Economic Opportunity Act of 1964 , 42 U.S.C.S. §§ 2763-2768, repealed by 86 Stat. 703 (1972), which obligated them to provide training and one year of employment to disadvantaged unemployed individuals. Plaintiffs contended that they were third party beneficiaries to the contracts. The trial court sustained defendants' general demurrers to the complaint on the ground that plaintiffs lacked standing.

DISCUSSION

  • The appellate court affirmed and held that the benefits to be derived from defendants' performance were clearly intended not as gifts from the government to unemployed persons but as a means of executing the public purposes stated in the contracts and in the underlying legislation. 
  • It said plaintiffs were only incidental beneficiaries and as such had no right of recovery and no standing to sue.
CONCLUSION
The court affirmed dismissal of demurring defendants and held that plaintiff unemployed persons were only incidental beneficiaries to contracts made between defendant companies and the government, and as such had no right of recovery and no standing to sue.

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