The law in the United States has not been much affected be statute. Such statutes as exist are generally of limited application. Many States make a policy of life insurance for the benefit of a wife or a wife and children good against creditors,49 but these statutes are silent as to the respective rights of the beneficiary and promisee. In Massachusetts, however, the beneficiary of a life insurance policy is given a right of action.50 California,51 North Dakota,52 and South Dakota,53 Montana 54 and Idaho,55 have the same provision that "a contract made table right of a trustee from a mere con-tractual right.

493 Am. & Eng. Cyc, 2d ed., 981.

50Rev. L. c. 118, Sec.73.

51 Civ. Code, Sec. 1659.

52Comp. L. (1913), Civ. Code, Sec.5841.

53Comp. L. (1913), Civ. Code, Sec.1198.

54Rev. Codes (1907), Civ. Code, Sec.4970. But this seems to be very narrowly construed. McDonald v. American Nat. Bank, 25 Mont. 456, 65 Pac. 896.

55 Rev. Stat., Sec. 3221.

expressly for the benefit of a third person may be enforced by him at any time before the parties thereto rescind it." The Louisiana Code 56 allows suit by the beneficiary of a contract, and Virginia 57 and West Virginia 58 have the same provision that "if a covenant or promise be made for the sole benefit of a person with whom it is not made, or with whom it is made jointly with others, such person may maintain in his own name any action thereon which he might maintain in case it had been made with him only, and the consideration had moved from him to the party making such covenant or promise." The Georgia Code provides 59 that "if there be a valid consideration for the promise, it matters not from whom it is moved, the promisee may sustain his action though a stranger to the consideration."