Rice v. Manley

In Rice v. Manley, 66 NY 82 [1876] the Court of Appeals stated, "it matters not whether the false representations be made to the party injured or to a third party, whose conduct is thus influenced to produce the injury" (id. at 87). In that case, the plaintiff, Rice, contracted to purchase cheese, and the defendant, Manley, knowing of Rice's contract, fraudulently induced the cheese vendor to deliver the cheese to him, instead of to Rice, by falsely telling the vendor that Rice no longer desired the cheese (id.). Noting that Rice was damaged to the extent that he had lost the benefit of his bargain, the Court of Appeals upheld his fraud cause of action against the defendant, even though it was the cheese vendor, rather than the plaintiff, who had detrimentally relied on the defendant's fraudulent misrepresentation (id.). In Rice, the defendant was the party who allegedly received the quantity of cheese and not the plaintiff who made the actual consideration for the product (Rice, 66 NY at 87).