Regarding Seaver v. Ransom, 120 N.E. 639 (N.Y. 1918), [pp. 694 of "Contracts: Examples and Explanations"]:
The court of appeals held that the promise of the uncle to the aunt that the uncle would bequeath a house to the niece was a contract rather than a constructive trust, and gave judgment for the niece ruling that she could enforce the promise as a 3rd party beneficiary.
Why didn't the Statute of Frauds invalidate this contract?