four-corners rule in Indiana

2025The four corners rule states that where the language of a contract is unambiguous, the parties’ intent is to be determined by reviewing the language contained within the “four corners” of the contract, and “parol or extrinsic evidence is inadmissible to expand, vary, or explain the instrument unless there has been a showing of fraud, mistake, ambiguity, illegality, duress or undue influence.” Adams v. Reinaker, 808 N.E.2d 192, 196 (Ind. Ct. App. 2004).

2025The four corners rule states that where the language of a contract is unambiguous, the parties’ intent is to be determined by reviewing the language contained within the “four corners” of the contract, and “parol or extrinsic evidence is inadmissible to expand, vary, or explain the instrument unless there has been a showing of fraud, mistake, ambiguity, illegality, duress or undue influence.” Adams v. Reinaker, 808 N.E.2d 192, 196 (Ind. Ct. App. 2004).

2025“Indiana follows ‘the four corners rule’ that ‘extrinsic evi- dence is not admissible to add to, vary or explain the terms of a written in- strument if the terms of the instrument are susceptible of a clear and un- ambiguous construction.’” Univ. of S. Ind. Found. v. Baker, 843 N.E.2d 528 , Indiana Supreme Court | Case No. 25S-CR-294 | November 13, 2025 Page 10 of 11 532 (Ind. 2006) (quoting Hauck v. Second Nat'l Bank of Richmond, 286 N.E.2d 852, 861 (Ind. Ct. App. 1972)).

2023In Indiana, we follow “‘the four corners rule’ that ‘extrinsic evidence is not admissible to add to, vary or explain the terms of a written instrument if the terms of the instrument are susceptible of a clear and unambiguous construction.’” Id. (quoting Hauck v. Second Nat’l Bank of Richmond, 153 Ind. App. 245, 260 , 286 N.E.2d 852, 861 (1972)).

2025“Indiana follows ‘the four corners rule’ that ‘extrinsic evi- dence is not admissible to add to, vary or explain the terms of a written in- strument if the terms of the instrument are susceptible of a clear and un- ambiguous construction.’” Univ. of S. Ind. Found. v. Baker, 843 N.E.2d 528 , Indiana Supreme Court | Case No. 25S-CR-294 | November 13, 2025 Page 10 of 11 532 (Ind. 2006) (quoting Hauck v. Second Nat'l Bank of Richmond, 286 N.E.2d 852, 861 (Ind. Ct. App. 1972)).

2023In Indiana, we follow “‘the four corners rule’ that ‘extrinsic evidence is not admissible to add to, vary or explain the terms of a written instrument if the terms of the instrument are susceptible of a clear and unambiguous construction.’” Id. (quoting Hauck v. Second Nat’l Bank of Richmond, 153 Ind. App. 245, 260 , 286 N.E.2d 852, 861 (1972)).

2020See Smith v. State, 822 N.E.2d 193 , 202–03 (Ind. Ct. App. 2005) (“Generally, a party waives any issue raised on appeal where the party fails to develop a cogent argument or provide adequate citation to authority and portions of the record.”).

2014LLC v. CNX Gas Co., LLC, 276 Va. 346 , 666 S.E.2d 527, 531 (2008) (“When the writing, considered as a whole, is clear, unambiguous, and explicit, a court asked to interpret such a document should look no further than the four corners of the instrument.”). “[T]he prohibition against the use of parol evidence is by no means absolute.

2014LLC v. CNX Gas Co., LLC, 276 Va. 346 , 666 S.E.2d 527, 531 (2008) (“When the writing, considered as a whole, is clear, unambiguous, and explicit, a court asked to interpret such a document should look no further than the four corners of the instrument.”). “[T]he prohibition against the use of parol evidence is by no means absolute.

2014Fultz v. Delhaize Am., Inc., 677 S.E.2d 272, 274 (Va. 2009). 17 reviewing the language contained within the “four corners” of the contract and “parol or extrinsic evidence is inadmissible to expand, vary, or explain the instrument unless there has been a showing of fraud, mistake, ambiguity, illegality, duress or undue influence.” Adams v. Reinaker, 808 N.E.2d 192, 196 (Ind. Ct. App. 2004) (quotation omitted); Pocahontas Min.

2009Hilbert v. Conseco Servs., LLC, 836 N.E.2d 1001, 1008 (Ind.Ct.App.2005), trans. denied, cert. denied, 549 U.S. 884 , 127 S.Ct. 237 , 166 L.Ed.2d 147 (2006).

2007In re Stonecipher, 849 N.E.2d 1191, 1195 (Ind.Ct.App. 2006); see Baker, 843 N.E.2d at 535 n. 2 (recognizing that although the Restatement Third of Property: Wills & Other Donative Transfers rejects the four-corners rule, Indiana still follows the rule).

1984Parol evidence is inadmissible where there is no ambiguity in the language. - American Fletcher National Bank v. Pavilion, Inc., (1982), Ind.App., 434 N.E.2d 896, 904 (vacated on other grounds, Ind., 458 N.E.2d 156 ); Hauck v. Second National Bank of Richmond (1972), 153 Ind.App. 245 , 286 N.E.2d 852, 861 .