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20 Virginia opinions name it 8 courts 1964–2024 5 in the last five years
The cases below were cited by Virginia courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
High Knob, Inc. v. Allengreen2 sentences1998In doing so, we recognized an exception to the parol evidence rule commonly called the “partial integration doctrine.” In High Knob, Inc. v. Allen, 205 Va. 503 , 138 S.E.2d 49 , (1964), we explained that the partial integration doctrine recognizes that the final form of a contract between parties may not reflect the complete agreement of the parties or accurately reflect the course of dealing between parties based on their complete agreement. 1998In doing so, we recognized an exception to the parol evidence rule commonly called the “partial integration doctrine.” In High Knob, Inc. v. Allen, 205 Va. 503 , 138 S.E.2d 49 , (1964), we explained that the partial integration doctrine recognizes that the final form of a contract between parties may not reflect the complete agreement of the parties or accurately reflect the course of dealing between parties based on their complete agreement. | 4 | 6 |
Renner Plumbing, Heating & Air Conditioning, Inc. v. Rennergreen2 sentences1991In Renner Plumbing, Heating & Air Con. v. Renner, 225 Va. 508, 515 , 303 S.E.2d 894, 898 (1983), the court stated: A well-recognized exception to the parol evidence rule, however, is the partial integration doctrine. 1991In Renner Plumbing, Heating & Air Con. v. Renner, 225 Va. 508, 515 , 303 S.E.2d 894, 898 (1983), the court stated: A well-recognized exception to the parol evidence rule, however, is the partial integration doctrine. | 3 | 3 |
Anden Group v. Leesburg Joint Venturegreen2 sentences2022Worsham, 74 Va. App. at 173 (alteration in original) (quoting Anden Grp. v. Leesburg Joint Venture, 237 Va. 453, 458 (1989)). 2022Worsham, 74 Va. App. at 173 (alteration in original) (quoting Anden Grp. v. Leesburg Joint Venture, 237 Va. 453, 458 (1989)). | 2 | 2 |
Shevel's, Inc. v. Southeastern Associates, Inc.green2 sentences2022Assocs., Inc., 228 Va. 175, 183 (1984) (noting that a merger clause “may impose . . . a heavy burden of persuasion” on the party claiming partial-integration status); Sinclair, supra § 19-2[a] (“Formal agreements, especially those with an integration clause, are treated as complete.”). - 10 - SunTrust Bank, 296 Va. 367, 376-77 (2018) (quoting Babcock & Wilcox Co. v. Areva NP, Inc., 292 Va. 165 , 180 n.8 (2016)). “[E]very word, clause, and provision of the [contract] ‘should be considered and construed together and seemingly conflicting provisions harmonized when that can be reasonably done, so 1986Ibid. | 1 | 2 |
Dickerson v. Commonwealthgreen2 sentences2024In closing, Integrated Composite argued, in relevant part, that the distribution agreement “encompasse[d] the same product, the same parties, the same terms”; that there “was no separate contract”; that the distribution agreement “limit[ed] the damages”; that the distribution agreement contained an integration clause which precluded collateral contracts; and that records existed showing that “thirty-one units [of the UHPC Premier had ordered] were consumed out of the fifty.” Although “an appropriate argument made during closing . . . will preserve a challenge to the sufficiency of the evidence 2024In closing, Integrated Composite argued, in relevant part, that the distribution agreement “encompasse[d] the same product, the same parties, the same terms”; that there “was no separate contract”; that the distribution agreement “limit[ed] the damages”; that the distribution agreement contained an integration clause which precluded collateral contracts; and that records existed showing that “thirty-one units [of the UHPC Premier had ordered] were consumed out of the fifty.” Although “an appropriate argument made during closing . . . will preserve a challenge to the sufficiency of the evidence | 1 | 1 |
Sweely Holdings, LLC v. Suntrust Bankgreen1 sentence2022Assocs., Inc., 228 Va. 175, 183 (1984) (noting that a merger clause “may impose . . . a heavy burden of persuasion” on the party claiming partial-integration status); Sinclair, supra § 19-2[a] (“Formal agreements, especially those with an integration clause, are treated as complete.”). - 10 - SunTrust Bank, 296 Va. 367, 376-77 (2018) (quoting Babcock & Wilcox Co. v. Areva NP, Inc., 292 Va. 165 , 180 n.8 (2016)). “[E]very word, clause, and provision of the [contract] ‘should be considered and construed together and seemingly conflicting provisions harmonized when that can be reasonably done, so | 1 | 1 |
Jim Carpenter Company v. Pottsgreen2 sentences1999In such circumstances, "where the entire agreement has not been reduced to writing, parol evidence is admissible, not to contradict or vary its terms but to show additional independent facts contemporaneously agreed upon, in order to establish the entire contract between the parties." Jim Carpenter Co. v. Potts, 255 Va. 147, 155-56 , 495 S.E.2d 828, 833 (1998) (citation omitted). 1999In such circumstances, "where the entire agreement has not been reduced to writing, parol evidence is admissible, not to contradict or vary its terms but to show additional independent facts contemporaneously agreed upon, in order to establish the entire contract between the parties." Jim Carpenter Co. v. Potts, 255 Va. 147, 155-56 , 495 S.E.2d 828, 833 (1998) (citation omitted). | 1 | 1 |
Gibbs v. Pricegreen1 sentence1995Another exception, which arises on proof of the mutual mistake of die parties, states that “equity should give effect to the true intent of the parties, despite a contrary intent reflected by a writing the parties mistakenly believed to monument their bargain.” Gibbs v. Price, 207 Va. 448, 449-50 (1966). | 1 | 1 |
Lindsay v. Bevinsgreen2 sentences1991See also, Lindsay v. Bevins, 204 Va. 74 , 128 S.E.2d 920 (1963). 2 In High Knob, Inc. v. Allen, 205 Va. 503, 506-507 , 138 S.E.2d 49, 52 (1964), the court stated: Another exception to the rule, which is similar in many respects to the partial integration doctrine, is the collateral contract doctrine. 1991See also, Lindsay v. Bevins, 204 Va. 74 , 128 S.E.2d 920 (1963). 2 In High Knob, Inc. v. Allen, 205 Va. 503, 506-507 , 138 S.E.2d 49, 52 (1964), the court stated: Another exception to the rule, which is similar in many respects to the partial integration doctrine, is the collateral contract doctrine. | 1 | 1 |
Durham v. National Pool Equipment Co.green1 sentence1983The parol evidence rule dictates that "parol evidence of prior or contemporaneous oral negotiations or stipulations is inadmissible to alter, vary, contradict, add to, subtract from or explain the terms of a complete, unambiguous, unconditional written instrument." Durham v. National Pool Equipment Company of Virginia, Inc., 205 Va. 441, 446 (1964). | 1 | 1 |
Reed v. Dentgreen2 sentences1964Farmers Manufacturing Co. v. Woodworth, 109 Va. 596, 601 , 64 S. E. 986, 988 ; Tuley v. Barton, 79 Va. 387, 392 ; Reed v. Dent, 194 Va. 156, 163 , 72 S. E. 2d 255, 258, 259 ; 20 Am. 1964Farmers Manufacturing Co. v. Woodworth, 109 Va. 596, 601 , 64 S. E. 986, 988 ; Tuley v. Barton, 79 Va. 387, 392 ; Reed v. Dent, 194 Va. 156, 163 , 72 S. E. 2d 255, 258, 259 ; 20 Am. | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Virginia. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Blackledge v. Allison
green
1 sentence2024Resolving this case on the grounds raised by Haysbert required a full hearing or trial on the merits.2 See Stockbridge, 269 Va. at 618 . 2 In his appeal, Word also argues that the circuit court erred by considering parol evidence despite the promissory note’s integration clause, which provides, “There are no verbal or other agreements which modify or affect the terms of this Note.” Word contends that in ruling on Haysbert’s summary judgment motion, the circuit court should not have considered Starpoint documents provided by Haysbert, and Word cites Blackledge v. Allison, 431 U.S. 63 (1977), an | 1 | 2024–2024 |
Stockbridge v. Gemini Air Cargo, Inc.
green
1 sentence2024Resolving this case on the grounds raised by Haysbert required a full hearing or trial on the merits.2 See Stockbridge, 269 Va. at 618 . 2 In his appeal, Word also argues that the circuit court erred by considering parol evidence despite the promissory note’s integration clause, which provides, “There are no verbal or other agreements which modify or affect the terms of this Note.” Word contends that in ruling on Haysbert’s summary judgment motion, the circuit court should not have considered Starpoint documents provided by Haysbert, and Word cites Blackledge v. Allison, 431 U.S. 63 (1977), an | 1 | 2024–2024 |
Cave Hill Corp. v. Hiers
green
1 sentence2024In arguing its motion to strike to the trial court, Integrated Composite emphasized a few specific issues raised in its written motion.8 Namely, Integrated Composite argued that there was no oral contract because a written contract existed and that, under Cave Hill Corp. v. Hiers, 264 Va. 640 (2002), Premier improperly used extrinsic “evidence to explain, modify an existing 8 In its written motion to strike, Integrated Composite made several arguments focusing on a handful of provisions in the distribution agreement which it contended were relevant to the dispute, including the agreement’s res | 1 | 2024–2024 |
Babcock & Wilcox Co. v. Areva NP, Inc.
green
1 sentence2022Assocs., Inc., 228 Va. 175, 183 (1984) (noting that a merger clause “may impose . . . a heavy burden of persuasion” on the party claiming partial-integration status); Sinclair, supra § 19-2[a] (“Formal agreements, especially those with an integration clause, are treated as complete.”). - 10 - SunTrust Bank, 296 Va. 367, 376-77 (2018) (quoting Babcock & Wilcox Co. v. Areva NP, Inc., 292 Va. 165 , 180 n.8 (2016)). “[E]very word, clause, and provision of the [contract] ‘should be considered and construed together and seemingly conflicting provisions harmonized when that can be reasonably done, so | 1 | 2022–2022 |
Zimbovsky v. Massachusetts
green
1 sentence2009The Commonwealth responds by citing our prior decisions in Juniper and Burns , as well as Cherrix v. Commonwealth, 257 Va. 292 , 513 S.E.2d 642 , cert. denied, 528 U.S. 873 , 120 S.Ct. 177 , 145 L.Ed.2d 149 (1999), and Walker v. Commonwealth, 258 Va. 54 , 515 S.E.2d 565 (1999), cert. denied, 528 U.S. 1125 , 120 S.Ct. 955 , 145 L.Ed.2d 829 (2000). | 1 | 2009–2009 |
Nagib v. Conner
green
1 sentence2009The Commonwealth responds by citing our prior decisions in Juniper and Burns , as well as Cherrix v. Commonwealth, 257 Va. 292 , 513 S.E.2d 642 , cert. denied, 528 U.S. 873 , 120 S.Ct. 177 , 145 L.Ed.2d 149 (1999), and Walker v. Commonwealth, 258 Va. 54 , 515 S.E.2d 565 (1999), cert. denied, 528 U.S. 1125 , 120 S.Ct. 955 , 145 L.Ed.2d 829 (2000). | 1 | 2009–2009 |
Scholl v. United States
green
1 sentence2009The Commonwealth responds by citing our prior decisions in Juniper and Burns , as well as Cherrix v. Commonwealth, 257 Va. 292 , 513 S.E.2d 642 , cert. denied, 528 U.S. 873 , 120 S.Ct. 177 , 145 L.Ed.2d 149 (1999), and Walker v. Commonwealth, 258 Va. 54 , 515 S.E.2d 565 (1999), cert. denied, 528 U.S. 1125 , 120 S.Ct. 955 , 145 L.Ed.2d 829 (2000). | 1 | 2009–2009 |
Ibrahim v. New York State Department of Health
green
1 sentence2009The Commonwealth responds by citing our prior decisions in Juniper and Burns , as well as Cherrix v. Commonwealth, 257 Va. 292 , 513 S.E.2d 642 , cert. denied, 528 U.S. 873 , 120 S.Ct. 177 , 145 L.Ed.2d 149 (1999), and Walker v. Commonwealth, 258 Va. 54 , 515 S.E.2d 565 (1999), cert. denied, 528 U.S. 1125 , 120 S.Ct. 955 , 145 L.Ed.2d 829 (2000). | 1 | 2009–2009 |
Harris v. Georgia
green
1 sentence2009The Commonwealth responds by citing our prior decisions in Juniper and Burns , as well as Cherrix v. Commonwealth, 257 Va. 292 , 513 S.E.2d 642 , cert. denied, 528 U.S. 873 , 120 S.Ct. 177 , 145 L.Ed.2d 149 (1999), and Walker v. Commonwealth, 258 Va. 54 , 515 S.E.2d 565 (1999), cert. denied, 528 U.S. 1125 , 120 S.Ct. 955 , 145 L.Ed.2d 829 (2000). | 1 | 2009–2009 |
Cherrix v. Commonwealth
green
2 sentences2009The Commonwealth responds by citing our prior decisions in Juniper and Burns , as well as Cherrix v. Commonwealth, 257 Va. 292 , 513 S.E.2d 642 , cert. denied, 528 U.S. 873 , 120 S.Ct. 177 , 145 L.Ed.2d 149 (1999), and Walker v. Commonwealth, 258 Va. 54 , 515 S.E.2d 565 (1999), cert. denied, 528 U.S. 1125 , 120 S.Ct. 955 , 145 L.Ed.2d 829 (2000). 2009The Commonwealth responds by citing our prior decisions in Juniper and Burns , as well as Cherrix v. Commonwealth, 257 Va. 292 , 513 S.E.2d 642 , cert. denied, 528 U.S. 873 , 120 S.Ct. 177 , 145 L.Ed.2d 149 (1999), and Walker v. Commonwealth, 258 Va. 54 , 515 S.E.2d 565 (1999), cert. denied, 528 U.S. 1125 , 120 S.Ct. 955 , 145 L.Ed.2d 829 (2000). | 1 | 2009–2009 |
Walker v. Commonwealth
green
2 sentences2009The Commonwealth responds by citing our prior decisions in Juniper and Burns , as well as Cherrix v. Commonwealth, 257 Va. 292 , 513 S.E.2d 642 , cert. denied, 528 U.S. 873 , 120 S.Ct. 177 , 145 L.Ed.2d 149 (1999), and Walker v. Commonwealth, 258 Va. 54 , 515 S.E.2d 565 (1999), cert. denied, 528 U.S. 1125 , 120 S.Ct. 955 , 145 L.Ed.2d 829 (2000). 2009The Commonwealth responds by citing our prior decisions in Juniper and Burns , as well as Cherrix v. Commonwealth, 257 Va. 292 , 513 S.E.2d 642 , cert. denied, 528 U.S. 873 , 120 S.Ct. 177 , 145 L.Ed.2d 149 (1999), and Walker v. Commonwealth, 258 Va. 54 , 515 S.E.2d 565 (1999), cert. denied, 528 U.S. 1125 , 120 S.Ct. 955 , 145 L.Ed.2d 829 (2000). | 1 | 2009–2009 |
Armentrout v. French
green
1 sentence2000Assuming these allegations to be true, the Court finds that a buyer’s decision to rely on such a statement is not reasonable, particularly in the face of a document that openly indicates otherwise, and also contains an integration clause stating no “prior or contemporaneous stipulations, representations, contracts, or promises except those... in the contract are the basis of [the] contract.” Nor can the Court find that such a statement diverts the purchaser from making the inquiries “which a prudent man ought to make." Armentrout v. French, 220 Va. 458 at 466 . | 1 | 2000–2000 |
Marriott v. Harris
green
2 sentences1993It appears that recognition of the salutary anti-fraud provisions of the Interstate Land Sales Act led the Virginia Supreme Court in Marriott v. Harris, 235 Va. 199 , 368 S.E.2d 225 (1988), to hold that the HUD statements were part of the purchasers’ contract even though the purchasers’ contract contained an integration clause and did not expressly incorporate by reference the HUD statements. 1993It appears that recognition of the salutary anti-fraud provisions of the Interstate Land Sales Act led the Virginia Supreme Court in Marriott v. Harris, 235 Va. 199 , 368 S.E.2d 225 (1988), to hold that the HUD statements were part of the purchasers’ contract even though the purchasers’ contract contained an integration clause and did not expressly incorporate by reference the HUD statements. | 1 | 1993–1993 |
Slaughter v. Smither
green
2 sentences1983Notwithstanding the holding in Slaughter v. Smither, 97 Va. 202 , 33 S.E. 544 (1899), I am of opinion that the partial integration doctrine is applicable to this case. 1983Notwithstanding the holding in Slaughter v. Smither, 97 Va. 202 , 33 S.E. 544 (1899), I am of opinion that the partial integration doctrine is applicable to this case. | 1 | 1983–1983 |
Tuley v. Barton
green
1 sentence1964Farmers Manufacturing Co. v. Woodworth, 109 Va. 596, 601 , 64 S. E. 986, 988 ; Tuley v. Barton, 79 Va. 387, 392 ; Reed v. Dent, 194 Va. 156, 163 , 72 S. E. 2d 255, 258, 259 ; 20 Am. | 1 | 1964–1964 |
Farmers Manufacturing Co. v. Woodworth
green
2 sentences1964Farmers Manufacturing Co. v. Woodworth, 109 Va. 596, 601 , 64 S. E. 986, 988 ; Tuley v. Barton, 79 Va. 387, 392 ; Reed v. Dent, 194 Va. 156, 163 , 72 S. E. 2d 255, 258, 259 ; 20 Am. 1964Farmers Manufacturing Co. v. Woodworth, 109 Va. 596, 601 , 64 S. E. 986, 988 ; Tuley v. Barton, 79 Va. 387, 392 ; Reed v. Dent, 194 Va. 156, 163 , 72 S. E. 2d 255, 258, 259 ; 20 Am. | 1 | 1964–1964 |
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.
Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.