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Cochran v. Robinhood Lane Baptist Church - No. W2004-01866-COA-R3-CV, 2005 Tenn. App. LEXIS 814 (Ct. App. Dec. 27, 2005)


To establish that one is an intended beneficiary of an employment agreement between two other parties, the beneficiary must establish (1) a valid contract made upon sufficient consideration between the principal parties and (2) the clear intent to have the contract operate for her benefit. In order to establish an intent to benefit, the beneficiary must show an expression in the contract that the contracting parties intended to benefit the third party or proof that the promisor's performance would otherwise discharge a duty owed to a third party beneficiary by the promise.


Cochran filed an action to seek injunctive relief and/ or damages for breach of contract and declaratory judgment against defendants. Cochran is the widow of the head pastor who, before his death, spoke to several deacons of the defendant church and requested that the church provide for his wife when able. Defendant church agreed to provide Cochran subject to certain terminating conditions. After a few years, defendant church discontinued making payments to Cochran, prompting the latter to file a suit. The court granted summary judgment in favor of the defendants, finding that there was no consideration to support the spouse benefits agreements between the parties.


Is the Spouse Benefits agreement between the parties supported by a valid consideration?




The Court determined that the church and officials did not benefit from the widow's presence at the church. She did not take on any additional responsibilities with the church nor promise to continue her activities with the church. The widow did not have a right to the benefits conferred to her pursuant to the employment contract between the pastor and the church. There was no original provision or oral modification of the employment contract that would have extended the life of the contract beyond the death of the pastor. Because the widow had no rights to the benefits conferred to her, her subsequent relinquishment of those benefits could not constitute consideration.

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