Stratton v. Inspiration Consolidated Copper Co
In Stratton v. Inspiration Consolidated Copper Co., 140 Ariz. 528, 531, 683 P.2d 327, 330 (App. 1984), a subcontractor sued the project owner after a general contractor failed to pay for the work done. 140 Ariz. at 529-30, 683 P.2d at 328-29.
The lack of privity between the subcontractor and the project owner barred the claim:
"Since there was no privity of contract between appellant and . . . appellant has no claim for a personal judgment sounding in breach of contract." Id. at 530-31.
The Court reached the same result in a different context in Leal. Leal v. Allstate Ins. Co., 199 Ariz. 250, 254, P21, 17 P.3d 95, 99 (App. 2000) was injured in an accident caused by Allstate's insured. 199 Ariz. at 251-52, PP3-7, 17 P.3d at 96-97.
When Allstate failed to make a satisfactory settlement offer, Leal sued for bad faith. Id. at 252, 17 P.3d at 97. The Court held that insurance bad faith derives from an insurance contract and "a stranger to the contract" cannot bring an action under it absent an assignment. 199 Ariz. at 254, P21, 17 P.3d at 99.