California Codes

Cal. Civil Code § 1625 (2026)

✓ current as of May 2026

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The execution of a contract in writing, whether the law requires it to be written or not, supersedes all the negotiations or stipulations concerning its matter which preceded or accompanied the execution of the instrument.

Notes of Decisions

Cited in 106 cases (16 in the last 5 years), 1921–2026 · leading case: Helm Fin. Corp. v. Iowa N. Ry. Co., 214 F. Supp. 2d 934 (N.D. Iowa 2002).

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Helm Fin. Corp. v. Iowa N. Ry. Co., 214 F. Supp. 2d 934 (N.D. Iowa 2002). · cites it 3× “IANR contends that the written lease was amended by various oral promises — or that there are genuine issues of material fact concerning oral amendments — including a promise to “make things right,” when IANR found that the locomotives were defective.”

Casa Herrera, Inc. v. Beydoun, 83 P.3d 497 (Cal. 2004). “4 Civil Code section 1625 provides that: “The execution of a contract in writing, whether the law requires it to be written or not, supersedes all the negotiations or stipulations concerning its matter which preceded or accompanied the execution of the instrument.”

Riverisland Cold Storage, Inc. v. Fresno-Madera Prod. Credit Ass'n, 13 Cal. Daily Op. Serv. 501 (Cal. 2013). “Civil Code section 1625 states: “The execution of a contract in writing, whether the law requires it to be written or not, supersedes all the negotiations or stipulations concerning its matter which preceded or accompanied the execution of the instrument.”

Masterson v. Sine, 436 P.2d 561 (Cal. 1968). · cites it 2× “, § 1856; Civ. Code, § 1625.) When only part of the agreement is integrated, the same rule applies to that part, but parol evidence may be used to prove elements of the agreement not reduced to writing.”

Copart, Inc. v. Sparta Consulting, Inc., 339 F. Supp. 3d 959 (E.D. Cal. 2018). “§ 1856 and Cal. Civ. Code § 1625 ). This rule, commonly called the parol evidence rule, is a rule of substantive law, not of procedure.”

Coyne v. De Leo, 237 Cal. Rptr. 3d 359 (Cal. Ct. App. 5th 2018). “Martin-Bragg certainly does not suggest that a disputed title issue relevant to possession should be passed altogether. The parol evidence rule generally prohibits the consideration of extrinsic evidence to vary or contradict the terms of an integrated written instrument.”

Carnegie Tech.. v. Triller, 39 F.4th 288 (5th Cir. 2022). “21-50912 In California, when there is a merger clause stating that the agreement is “the final expression of, and contains the entire agreement between, the parties[,]” extrinsic evidence of an alternative or additional agreement or of negotiations or stipulations cannot be used…”

Lennar Mare Island, LLC v. Steadfast Ins., 176 F. Supp. 3d 949 (E.D. Cal. 2016). “§ 1856 and Cal. Civ. Code § 1625 ). This rule, commonly called the parol evidence rule, is a rule of substantive law, not of procedure.”

Levy-zentner Co. v. S. Pac. Transp., 74 Cal. App. 3d 762 (Cal. Ct. App. 1977). “The second disallowed matter was whether the tenants had requested fire protection improvements while negotiating the terms of their leases with Southern Pacific. The trial court properly ruled that the leases obviously constituted the final embodiment and integration of the…”

Laux v. Freed, 348 P.2d 873 (Cal. 1960). · cites it 2× “(Civ. Code, § 1625; Hotle v. Miller, 51 Cal.”

Malmstrom v. Kaiser Aluminum & Chem. Corp., 2 I.E.R. Cas. (BNA) 180 (Cal. Ct. App. 1986). “(Civ. Code, § 1625; Code Civ. Proc., § 1856.”

Blumenfeld v. R. H. MacY & Co., 92 Cal. App. 3d 38 (Cal. Ct. App. 1979). “(Civ. Code, § 1625; Code Civ. Proc., § 1856; Rest.”

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