175 Ill. App. 3d 310 - Alaniz v. Schal Associates’s Empirical Analysis
1988
Citation profile
4 federal appellate · 16 state decisions
How this case has been cited
Cited by 24 later decisions — most recently March 2021
4 federal appellate · 16 state decisions
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Relies on 78 Ill. 2d 204 - Pippin v. Chicago Housing Authority · Carson Pirie Scott & Co. v. Parrett · 78 Ill. 2d 381 - People Ex Rel. Resnik v. Curtis & Davis, Architects & Planners, Inc. · James Stewart & Co. v. Law · 109 Ill. 2d 225 - Bates & Rogers Construction Corp. v. Greeley & Hansen
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 24 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““ ‘[T]he law regarding third-party beneficiaries is well established. A third-party beneficiary may sue for breach of a contract made for his benefit. [Citation.] A third party may only sue for breach of contract, however, if the contract was entered into for the party’s direct benefit; if the third-party’s benefit is merely incidental, he has no right of recovery on the contract. [Citations.] Whether a third party is a direct beneficiary depends on the intention of the parties, which must “be gleaned from a consideration of all of the contract and the circumstances surrounding the parties at the time of its execution.” [Citation.]’ ” People ex rel. Hartigan v. Community Hospital of Evanston, 189 Ill. App. 3d 206, 217 (1989), quoting Alaniz v. Schal Associates, 175 Ill. App. 3d 310, 312 (1988), quoting Carson Pirie Scott & Co. v. Parrett, 346 Ill. 252, 258 (1931).”
1 later decision quote this exact passage · from the majority““It is not enough that an incidental benefit will flow to third parties; only a direct beneficiary has a right under a contract. [Citation.] We believe that more than the general safety provision found in the contract between [the subcontractor] and [the general contractor] is required to evidence an intent to directly benefit plaintiff. While plaintiff would most likely have received some benefit by implementation of safety programs, such benefit is incidental to the direct benefit intended for the contracting parties, and thus is not sufficient to allow him to maintain an action on the contract. Plaintiffs action is better characterized as a tort action.” Alaniz, 175 Ill. App. 3d at 314-15 .”
1 later decision quote this exact passage · from the majority“between direct and incidental benefits as is required by Illinois law.”
1 later decision quote this exact passage · from the majority
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.