Code of Alabama
Ala. Code § 7-2-202 (2026)
Final Expression: Parol or Extrinsic Evidence.
✓ official Alabama Legislature (ALISON) text, current July 2026
Terms with respect to which the confirmatory memoranda of the parties agree or which are otherwise set forth in a record intended by the parties as a final expression of their agreement with respect to such terms as are included therein may not be contradicted by evidence of any prior agreement or of a contemporaneous oral agreement but may be explained or supplemented:
(a) by course of performance, course of dealing, or usage of trade (Section 7-1-303); and
(b) by evidence of consistent additional terms unless the court finds the record to have been intended also as a complete and exclusive statement of the terms of the agreement.
(Acts 1965, No. 549, p. 811; Act 2004-524, p. 1070, §2; Act 2023-492, §1.)
Notes of Decisions
Cited in 9
cases, 1983–2016 · leading case: S. Energy Homes, Inc. v. Washington, 774 So. 2d 505 (Ala. 2000).
S. Energy Homes, Inc. v. Washington, 774 So. 2d 505 (Ala. 2000). “Section 7-2-316 provides in pertinent part: "(1) Words or conduct relevant to the creation of an express warranty and words or conduct tending to negate or limit warranty shall be construed wherever reasonable as consistent with each other; but subject to the provisions of this…”
La Trace v. Webster, 17 So. 3d 1210 (Ala. Civ. App. 2008). “" Section 7-2-316(1) provides that an express warranty cannot be disclaimed by language in a sales contract: "Words or conduct relevant to the creation of an express warranty and words or conduct tending to negate or limit warranty shall be construed wherever reasonable as…”
Shutter Shop, Inc. v. Amersham Corp., 114 F. Supp. 2d 1218 (M.D. Ala. 2000). “CODE § 7-2-202 (1975). Cf. Alimenta (U.S.A.), Inc.”
Laferrera v. Camping World RV Sales, 171 F. Supp. 3d 1257 (N.D. Ala. 2016). “set forth in a writing intended by the parties as a final expression of their agreement with respect to such terms as are included therein may not be • contradicted by evidence of any prior agreement or of a contemporaneous oral agreement.”
Thorn's Diesel Serv., Inc. v. Houston Ship Repair, Inc., 233 F. Supp. 2d 1332 (M.D. Ala. 2002). “1988) (Alabama’s UCC parol evidence rule in section 7-2-202 does not bar introduction of subsequent agreements to a contract).”
Hunjan Moulded Prods. (Alabama) Ltd. v. Hunjan Moulded Prods. (Alabama), Ltd., 292 F. App'x 855 (11th Cir. 2008). “Ala.Code § 7-2-202. Because the quotations and purchase orders were consistent in their terms, parol evidence barred contradictory evidence.”
Ex Parte Mcclarty Const. & Equip. Co., Inc., 428 So. 2d 629 (Ala. 1983). “) Likewise, under Code 1975, § 7-2-202, the following is provided: "Terms with respect to which the confirmatory memoranda of the parties agree or which are otherwise set forth in a writing intended by the parties as a final expression of their agreement with respect to such…”
McClarty Constr. & Equip. Co. v. Mining, Ore & Equip. Co., 428 So. 2d 629 (Ala. 1983). “) Likewise, under Code 1975, § 7-2-202, the following is provided: “Terms with respect to which the confirmatory memoranda of the parties agree or which are otherwise set forth in a writing intended by the parties as a final expression of their agreement with respect to such…”
Am. Carpet Sales, Inc. v. World Carpets, Inc., 477 So. 2d 974 (Ala. Civ. App. 1985). “Under Ala.Code (1975), § 7-2-202 usage of trade, which we interpret to include industry custom (see Ala.”
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