parol evidence rule (Kentucky) · Go Syfert
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parol evidence rule in Kentucky

19 Kentucky opinions name it 3 courts 1935–2026 4 in the last five years

The cases below were cited by Kentucky 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.

Followed or applied (9)

CaseFollowedCited
Childers & Venters, Inc. v. Sowardsgreen
kyctapphigh · 1970 · cited in 3 Kentucky opinions naming this issue, 2007–2022
2 sentences

2022Childers and Venters, Inc. v. Sowards, 460 S.W.2d 343, 345 (Ky. 1970).

2009Childers and Venters, Inc. v. Sowards, 460 S.W.2d 343, 345 (Ky.1970).

33
Johnson v. Johnsongreen
kyctapphigh · 1944 · cited in 2 Kentucky opinions naming this issue, 1970–1982
2 sentences

1982Johnson v. Johnson, 297 Ky. 268 , 178 S.W.2d 983 (1944); 30 Am.Jur.2d Evidence §§ 1017, 1022, 1028.

1982Johnson v. Johnson, 297 Ky. 268 , 178 S.W.2d 983 (1944); 30 Am.Jur.2d Evidence §§ 1017, 1022, 1028.

12
Haynes v. Froehlichgreen
kyctapp · 1954 · cited in 1 Kentucky opinions naming this issue, 2026–2026
1 sentence

2026“It is well settled that evidence of a contemporaneous parol promise made to the payor of a note that he would not be bound by it is inadmissible and will not be permitted to defeat the positive and unqualified written promise of a promissory note.” Haynes v. Froehlich, 273 S.W.2d 379, 380 (Ky. 1954) (citation omitted). -16- We have addressed the balance of Sub Club’s cognizable arguments of error regarding Resing’s breach of contract claim.

11
Texas Gas Transmission Corp. v. Kinslowgreen
kyctapp · 1970 · cited in 1 Kentucky opinions naming this issue, 2022–2022
1 sentence

2022Johnson cites to Texas Gas Transmission Corporation v. Kinslow, 461 S.W.2d 69, 71 (Ky. 1970), to argue that the oral agreement was a collateral contract and thus not subject to the parol evidence rule: The basic rule applicable is thus stated in 30 Am.Jur.2d, Evidence, Section 1049, page 184: ‘An exception to the parol evidence rule, which is similar in many respects to that of the doctrine of partial integration, is known as the ‘doctrine of collateral contract.’ Under this doctrine, a prior or contemporaneous oral contract which is independent of, collateral to, and not inconsistent with, th

11
Murray v. Boydgreen
kyctapp · 1915 · cited in 1 Kentucky opinions naming this issue, 2017–2017
2 sentences

2017See Murray v. Boyd , 165 Ky. 625 , 177 S.W. 468 , 471 (1915) ("It is a well-settled rule that a contract not required to be in writing may be discharged or modified by subsequent oral agreement, and that the parol evidence rule does not exclude oral evidence thereof in a proper case.").

2017See Murray v. Boyd , 165 Ky. 625 , 177 S.W. 468 , 471 (1915) ("It is a well-settled rule that a contract not required to be in writing may be discharged or modified by subsequent oral agreement, and that the parol evidence rule does not exclude oral evidence thereof in a proper case.").

11
Humphries v. Haydongreen
kyctapphigh · 1944 · cited in 1 Kentucky opinions naming this issue, 2009–2009
2 sentences

2009Humphries v. Haydon, 297 Ky. 219 , 179 S.W.2d 895, 897 (1944).

2009Humphries v. Haydon, 297 Ky. 219 , 179 S.W.2d 895, 897 (1944).

11
Hanson v. American National Bank & Trust Co.green
ky · 1993 · cited in 1 Kentucky opinions naming this issue, 2007–2007
1 sentence

2007Hanson v. American National Bank & Trust Co., 865 S.W.2d 302, 307 (Ky.1993), overruled on other grounds by, Sand Hill Energy, Inc. v. Ford Motor Co., 83 S.W.3d 483 (Ky.2002).

11
Potts v. Drapergreen
ky · 1993 · cited in 1 Kentucky opinions naming this issue, 1997–1997
1 sentence

1997Potts v. Draper, Ky., 864 S.W.2d 896, 899 (1993).

11
Ross Seed Co. v. Sturgis Implement & Hardware Co.green
kyctapphigh · 1944 · cited in 1 Kentucky opinions naming this issue, 1951–1951
2 sentences

1951See Ross Seed Co. v. Sturgis Implement & Hardware Co., 297 Ky. 776 , 181 S.W.2d 426 .

1951See Ross Seed Co. v. Sturgis Implement & Hardware Co., 297 Ky. 776 , 181 S.W.2d 426 .

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Kentucky. Read the followed side critically anyway.

Also cited on this issue (16)

CaseCitedYears
Adams v. Fada Realty Co. green
kyctapphigh · 1947
2 sentences

1964Adams v. Fada Realty Co., 305 Ky. 195 , 202 S.W.2d 439 .

1964Adams v. Fada Realty Co., 305 Ky. 195 , 202 S.W.2d 439 .

21954–1964
McNamara v. McNamara neutral
kyctapphigh · 1942
1 sentence

2022Beyond Campbell discussed above, Gray cites McNamara v. Marcum, 162 S.W.2d 205 (Ky. 1942), and Mahaffey v. Wilson, 317 S.W.2d 888 (Ky. 1958), as authority supporting his argument that (1) the contract is not lacking in certainty as the parties 26 identified the land even if it had not yet been designated by surveyed legal description, and (2) the instrument or other evidence is not required to fix the boundary lines of the property.

12022–2022
Mahaffey v. Wilson green
kyctapp · 1958
1 sentence

2022Beyond Campbell discussed above, Gray cites McNamara v. Marcum, 162 S.W.2d 205 (Ky. 1942), and Mahaffey v. Wilson, 317 S.W.2d 888 (Ky. 1958), as authority supporting his argument that (1) the contract is not lacking in certainty as the parties 26 identified the land even if it had not yet been designated by surveyed legal description, and (2) the instrument or other evidence is not required to fix the boundary lines of the property.

12022–2022
Radioshack Corp. v. ComSmart, Inc. green
kyctapp · 2007
1 sentence

2022“The parol evidence rule is not a procedural device but, rather, a substantive rule of law that prevents the introduction of oral statements into evidence to alter a written agreement, per force lending integrity to writings.” Id. at 261 .

12022–2022
New Life Cleaners v. Tuttle green
kyctapp · 2009
2 sentences

2022New Life Cleaners, 292 S.W.3d at 322-23 .

2022In New Life Cleaners v. Tuttle, 292 S.W.3d 318 (Ky. App. 2009), this Court explained the doctrine as follows: Parol evidence has been defined as oral evidence rather than written evidence.

12022–2022
Sand Hill Energy, Inc. v. Ford Motor Co. green
ky · 2002
1 sentence

2007Hanson v. American National Bank & Trust Co., 865 S.W.2d 302, 307 (Ky.1993), overruled on other grounds by, Sand Hill Energy, Inc. v. Ford Motor Co., 83 S.W.3d 483 (Ky.2002).

12007–2007
Harvey v. Moran's Adm'r neutral
kyctapp · 1952
1 sentence

1970Harvey v. Moran’s Adm’r, Ky., 245 S.W.2d 452 (1952).

11970–1970
Mario's Pizzeria, Inc. v. Federal Sign & Signal Corp. green
kyctapp · 1964
1 sentence

1970The signed contract was “ * * * the repository of the final understanding and the measure of the parties’ rights as a matter of substantive law.” Johnson v. Johnson, supra. Cf. Mario’s Pizzeria, Inc. v. Federal Sign and Signal Corp., Ky., 379 S.W.2d 736 (1964); 30 Am.Jur.2d 151, Evidence, section 1016. *10 The parol evidence rule is not referred to or discussed in the briefs presented to us therefore we do not examine it or determine how it might apply to the issues presented here.

11970–1970
Gibson v. Sellars green
kyctapphigh · 1952
1 sentence

1968Cf. Gibson v. Sellars, Ky., 252 S.W.2d 911, 913 , 37 A.L.R.2d 1435 (1952).

11968–1968
Smith v. Ferguson neutral
kyctapp · 1956
1 sentence

1966Ap-pellee further contends that the parol evidence rule providing that all prior agreements are merged in the written contract should be invoked and cites Smith v. Ferguson, Ky., 295 S.W.2d 792 , in support thereof.

11966–1966
Dunn v. Tate green
kyctapphigh · 1954
1 sentence

1964In the case of Dunn v. Tate, Ky., 268 S.W.2d 925 , we find the following statement: “Tate recognizes the general rule that false and fraudulent representations made by a vendor to induce the purchaser to enter into the contract are not merged in the contract, and that proof of such representations is not barred by the parol evidence rule.

11964–1964
Querry v. White neutral
kyctapp · 1808
2 sentences

1954Querry v. White, 4 Ky. 271 , 1 Bibb 271 ; Doyle v. Offutt & Blackburn, 135 Ky. 296 , 122 S.W. 156 ; Aufenkamp v. Storch, 138 Ky. 104 , 127 S.W. 529 .

1954Querry v. White, 4 Ky. 271 , 1 Bibb 271 ; Doyle v. Offutt & Blackburn, 135 Ky. 296 , 122 S.W. 156 ; Aufenkamp v. Storch, 138 Ky. 104 , 127 S.W. 529 .

11954–1954
Doyle v. Offutt green
· 1909
2 sentences

1954Querry v. White, 4 Ky. 271 , 1 Bibb 271 ; Doyle v. Offutt & Blackburn, 135 Ky. 296 , 122 S.W. 156 ; Aufenkamp v. Storch, 138 Ky. 104 , 127 S.W. 529 .

1954Querry v. White, 4 Ky. 271 , 1 Bibb 271 ; Doyle v. Offutt & Blackburn, 135 Ky. 296 , 122 S.W. 156 ; Aufenkamp v. Storch, 138 Ky. 104 , 127 S.W. 529 .

11954–1954
Aufenkamp v. Storch neutral
kyctapp · 1910
2 sentences

1954Querry v. White, 4 Ky. 271 , 1 Bibb 271 ; Doyle v. Offutt & Blackburn, 135 Ky. 296 , 122 S.W. 156 ; Aufenkamp v. Storch, 138 Ky. 104 , 127 S.W. 529 .

1954Querry v. White, 4 Ky. 271 , 1 Bibb 271 ; Doyle v. Offutt & Blackburn, 135 Ky. 296 , 122 S.W. 156 ; Aufenkamp v. Storch, 138 Ky. 104 , 127 S.W. 529 .

11954–1954
Apple v. McCullough green
kyctapphigh · 1931
2 sentences

1952The Carpenters brought this action under the authority given by KRS 371.030, which provides that: “The consideration of any writing, with or without seal, may be impeached or denied 'by pleading verified by oath.” The exception to the parol evidence rule made possible by this section applies only to the “consideration” of a .contract as distinguished from its “subject matter.” Apple v. McCullough, 239 Ky. 74 , 38 S.W.2d 955 .

1952The Carpenters brought this action under the authority given by KRS 371.030, which provides that: “The consideration of any writing, with or without seal, may be impeached or denied 'by pleading verified by oath.” The exception to the parol evidence rule made possible by this section applies only to the “consideration” of a .contract as distinguished from its “subject matter.” Apple v. McCullough, 239 Ky. 74 , 38 S.W.2d 955 .

11952–1952
Klatch v. Simpson green
kyctapphigh · 1931
2 sentences

1935If the •contract is required to be in writing, evidence will not be admitted to prove a subsequent parol agreement which materially modifies the writing; that is, if the subsequent agreement is itself within the statute of frauds, and of a nature required by law to be in writing.” As supporting the contention that the oral agreement, which it is claimed was made modifying the writ *60 ten contract is permissible under the statute of frauds, counsel for appellants cite and rely on the case of Klatch v. Simpson, 237 Ky. 84 , 34 S. W. (2d) 951 , and a number of other cases from this jurisdiction.

1935If the •contract is required to be in writing, evidence will not be admitted to prove a subsequent parol agreement which materially modifies the writing; that is, if the subsequent agreement is itself within the statute of frauds, and of a nature required by law to be in writing.” As supporting the contention that the oral agreement, which it is claimed was made modifying the writ *60 ten contract is permissible under the statute of frauds, counsel for appellants cite and rely on the case of Klatch v. Simpson, 237 Ky. 84 , 34 S. W. (2d) 951 , and a number of other cases from this jurisdiction.

11935–1935

Statutes the citing opinions construe

KY § Ky. Rev. Stat. § 371.030 (3)

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.

Where else courts name it

TX 601 (1916–2026) NY 399 (1906–2026) CA 342 (1922–2026) PA 301 (1921–2026) OH 234 (1937–2026) IL 153 (1877–2025) MO 143 (1909–2025) MI 126 (1938–2026) TN 118 (1932–2026) CT 115 (1930–2025) FL 111 (1928–2024) WA 108 (1916–2025) IA 96 (1916–2025) AZ 96 (1925–2025) NC 91 (1920–2026) GA 90 (1910–2025) OR 88 (1915–2021) VA 80 (1920–2025) AL 79 (1927–2018) LA 78 (1930–2018) MA 74 (1923–2026) MN 72 (1922–2025) IN 67 (1951–2020) UT 63 (1921–2026) AR 61 (1930–2024) MD 61 (1932–2025) SC 60 (1924–2025) NJ 59 (1926–2026) ND 53 (1926–2019) ID 49 (1978–2020) MT 48 (1920–2019) MS 47 (1922–2025) OK 47 (1924–2021) DE 46 (1954–2026) NE 46 (1921–2020) KS 46 (1914–2020) RI 42 (1951–2021) WY 41 (1926–2022) ME 38 (1928–2024) WV 35 (1922–2020) CO 35 (1924–2025) NM 34 (1933–2019) WI 31 (1934–2023) VT 29 (1916–2026) SD 26 (1929–2025) HI 25 (1962–2025) NV 21 (1957–2022) DC 20 (1950–2025) KY 19 (1935–2026) AK 18 (1971–2022) NH 16 (1948–2021) VI 3 (1988–2025)

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.

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