Smith v. Central Ariz. Water Conservation Dist.
Citation: 35 ELR 20164
No. No. 03-16962, (9th Cir., 08/10/2005)
The court holds that landowners residing within various irrigation districts in central Arizona may not seek declaratory relief to prevent modification of existing irrigation contracts between the Central Arizona Water Conservation District and the United States. The landowners are merely incidental beneficiaries to the contracts. Under federal law principles of contract interpretation, incidental beneficiaries may not assert claims predicated upon a federal contract in the absence of a clear intent to confer an enforceable benefit. In this case, neither the master contract nor the relevant subcontracts contain language evincing a clear intent to benefit the landowners. Thus, the landowners are not third-party beneficiaries, and their complaint was properly dismissed by the district court.