merger doctrine (Arkansas) · Go Syfert
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merger doctrine in Arkansas

14 Arkansas opinions name it 2 courts 1916–2025 3 in the last five years

The cases below were cited by Arkansas 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 (4)

CaseFollowedCited
Abernathy v. Stategreen
ark · 1983 · cited in 2 Arkansas opinions naming this issue, 2024–2025
2 sentences

2025See Hundley I, 2024 Ark. 19, at 6 , 682 S.W.3d at 670 (citing Abernathy v. State, 278 Ark. 250 , 644 S.W.2d 590 (1983)).

2025See Hundley I, 2024 Ark. 19, at 6 , 682 S.W.3d at 670 (citing Abernathy v. State, 278 Ark. 250 , 644 S.W.2d 590 (1983)).

12
Thernell Hundley v. Dexter Payne, Director, Arkansas Department of Correctiongreen
ark · 2024 · cited in 1 Arkansas opinions naming this issue, 2025–2025
1 sentence

2025See Hundley I, 2024 Ark. 19, at 6 , 682 S.W.3d at 670 (citing Abernathy v. State, 278 Ark. 250 , 644 S.W.2d 590 (1983)).

11
Alltel Corp. v. Sumnergreen
ark · 2005 · cited in 1 Arkansas opinions naming this issue, 2017–2017
2 sentences

2017Miesner also argues that there was no assent to the Agreement’s terms because the parties thought the document allowed only blood relatives to receive a benefit under the Agreement and “[m]utual assent to an agreement and its terms is a foundational requirement, which must be satisfied, for an enforceable agreement.” Relyance says the Agreement’s merger clause defeats Miesner’s argument and that she, her sister, and her mother were all represented by attorneys when the document was signed. “[T]o make a contract there must be a meeting of the minds as to all terms, using objective indicators.”

2017Miesner also argues that there was no assent to the Agreement’s terms because the parties thought the document allowed only blood relatives to receive a benefit under the Agreement and “[m]utual assent to an agreement and its terms is a foundational requirement, which must be satisfied, for an enforceable agreement.” Relyance says the Agreement’s merger clause defeats Miesner’s argument and that she, her sister, and her mother were all represented by attorneys when the document was signed. “[T]o make a contract there must be a meeting of the minds as to all terms, using objective indicators.”

11
Croswhite v. Rystromgreen
ark · 1974 · cited in 1 Arkansas opinions naming this issue, 2015–2015
2 sentences

2015See generally Croswhite v. Rystrom, 256 Ark. 156, 162 , 506 S.W.2d 830, 833 (1974) (“presumption is that all prior negotiations merge into the instrument, of conveyance”). • The parties in this case disagree on how to characterize Deed III, which is the “correction deed” that the circuit court reformed.

2015See generally Croswhite v. Rystrom, 256 Ark. 156, 162 , 506 S.W.2d 830, 833 (1974) (“presumption is that all prior negotiations merge into the instrument, of conveyance”). • The parties in this case disagree on how to characterize Deed III, which is the “correction deed” that the circuit court reformed.

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (12)

CaseCitedYears
Baily v. Eakes neutral
ark · 1925
2 sentences

1991Baily v. Eakes, 168 Ark. 872 , 271 S.W. 978 (1925).

1991Baily v. Eakes, 168 Ark. 872 , 271 S.W. 978 (1925).

21991–1991
Commonwealth Building and Loan Ass'n v. Martin green
ark · 1932
2 sentences

1991Id.

1991Id.

21991–1991
Altice USA, Inc., D/B/A Suddenlink Communications v. William Campbell green
arkctapp · 2023
1 sentence

2023That is, Johnson directs our conclusion that the RSA, as it appears on Suddenlink’s website, meets the FAA’s requirement that arbitration provisions must be written. 16 Johnson also compels our holding that the absence of a signed writing does not violate a recent amendment to the statute of frauds17 and that the invoices were competent proof of the Runyans’ assent, despite the RSA’s merger clause.18 Johnson also directs our conclusions that the Runyans’ challenges to the mutuality of obligation supporting the RSA as a whole are outside the scope of our review.19 That leaves the Runyans’ argum

12023–2023
Fort Smith Appliance & Service Co. v. Smith green
ark · 1951
2 sentences

2016Co. v. Smith, 218 Ark. 411 , 236 S.W.2d 583 (1951). ■ In support of its argument, Patton references the merger clause found at paragraph 12(f) of the Tri-Party Agreement: This Agreement (including the Exhibits to this Agreement) supercedes any other agreement, whether written or oral, that may have been made or entered into by any party or any of then- respective Affiliates ... relating to. the matters contemplated hereby.

2016Co. v. Smith, 218 Ark. 411 , 236 S.W.2d 583 (1951). ■ In support of its argument, Patton references the merger clause found at paragraph 12(f) of the Tri-Party Agreement: This Agreement (including the Exhibits to this Agreement) supercedes any other agreement, whether written or oral, that may have been made or entered into by any party or any of then- respective Affiliates ... relating to. the matters contemplated hereby.

12016–2016
Aceva Technologies, LLC v. Tyson Foods, Inc. green
arkctapp · 2013
1 sentence

2013Simpson, supra. The parol-evidence rule is a rule 10 Cite as 2013 Ark.

12013–2013
Hagans v. Haines green
arkctapp · 1998
2 sentences

2003App. 158 , 984 S.W.2d 41 (1998), wherein that court reversed a trial court’s decision to permit parol evidence regarding an oral rental agreement, even though the parties’ written rental agreement contained a merger clause.

2003The Bank again cites Hagans, 64 Ark.

12003–2003
Duncan v. McAdams neutral
ark · 1953
2 sentences

1993The rest of the sentence states, “however, if there be a showing of mutual mistake of fact, a misrepresentation, or perpetration of a fraud, the merger is not consummated.” Moreover, Croswhite v. Rystrom cites as authority the case of Duncan v. McAdams, 222 Ark. 143 , 257 S.W.2d 568 (1953), which quotes as authority a statement from American Jurisprudence that the doctrine of merger applies “in the absence of fraud or mistake, and in the absence of contractual provisions or agreements which are not intended to be merged in the deed.” From the testimony of the appellee, the chancellor could fin

1993The rest of the sentence states, “however, if there be a showing of mutual mistake of fact, a misrepresentation, or perpetration of a fraud, the merger is not consummated.” Moreover, Croswhite v. Rystrom cites as authority the case of Duncan v. McAdams, 222 Ark. 143 , 257 S.W.2d 568 (1953), which quotes as authority a statement from American Jurisprudence that the doctrine of merger applies “in the absence of fraud or mistake, and in the absence of contractual provisions or agreements which are not intended to be merged in the deed.” From the testimony of the appellee, the chancellor could fin

11993–1993
Protho v. Williams green
ark · 1921
2 sentences

1933Plaintiffs below, appellants here, cite and rely upon the case of Prothro v. Williams, 147 Ark. 535 , 229 S. W. 38 , as authorizing this suit.

1933Plaintiffs below, appellants here, cite and rely upon the case of Prothro v. Williams, 147 Ark. 535 , 229 S. W. 38 , as authorizing this suit.

11933–1933
Simpson v. Robinson green
ark · 1881
1 sentence

1932Simpson v. Robinson, 37 Ark. 132 .

11932–1932
Bemis v. First National Bank green
ark · 1897
1 sentence

1916The rule laid down by this court is that “the doctrine of merger never applies where there are any equities which will be thereby defeated.” Bemis v. First National Bank, 63 Ark. 625 ; Neff v. Elder, 84 Ark. 277 ; Beauchamp v. Bertig, 90 Ark. 351 .

11916–1916
Neff v. Elder green
ark · 1907
1 sentence

1916The rule laid down by this court is that “the doctrine of merger never applies where there are any equities which will be thereby defeated.” Bemis v. First National Bank, 63 Ark. 625 ; Neff v. Elder, 84 Ark. 277 ; Beauchamp v. Bertig, 90 Ark. 351 .

11916–1916
Beauchamp v. Bertig green
· 1909
1 sentence

1916The rule laid down by this court is that “the doctrine of merger never applies where there are any equities which will be thereby defeated.” Bemis v. First National Bank, 63 Ark. 625 ; Neff v. Elder, 84 Ark. 277 ; Beauchamp v. Bertig, 90 Ark. 351 .

11916–1916

Statutes the citing opinions construe

AR § Ark. Code Ann. § 16-22-308 (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

NY 473 (1823–2026) GA 286 (1933–2026) WA 272 (1927–2026) OH 245 (1896–2026) PA 232 (1906–2026) TX 217 (1888–2026) CA 168 (1919–2025) IL 100 (1900–2026) NC 73 (1920–2026) FL 70 (1938–2026) UT 68 (1945–2025) OR 64 (1977–2026) MA 63 (1921–2026) MD 60 (1962–2026) CO 59 (1895–2026) AL 56 (1872–2025) IA 53 (1883–2026) MO 49 (1894–2024) CT 48 (1979–2025) MI 43 (1894–2025) ID 41 (1959–2025) NJ 36 (1942–2025) KS 34 (1918–2026) VA 33 (1990–2025) TN 33 (1917–2026) DC 27 (1966–2024) HI 27 (1906–2026) MS 23 (1967–2023) KY 22 (1971–2025) MN 21 (1960–2017) AZ 19 (1927–2026) SC 19 (1981–2025) NM 19 (1943–2024) OK 18 (1930–2026) RI 18 (1989–2018) WV 16 (1987–2025) DE 15 (1930–2026) IN 14 (1878–2017) AR 14 (1916–2025) WY 13 (1951–2022) MT 13 (1980–2020) WI 13 (1901–2025) NH 13 (1988–2025) VT 10 (1996–2026) NE 10 (1926–2016) NV 8 (1985–2019) ME 7 (1976–2018) ND 6 (1984–2025) SD 6 (1980–2020) VI 4 (2008–2025) AK 2 (1989–2021)

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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