parole evidence rule (Missouri) · Go Syfert
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parole evidence rule in Missouri

14 Missouri opinions name it 2 courts 1950–2024 2 in the last five years

The cases below were cited by Missouri 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 (8)

CaseFollowedCited
Royal Banks of Missouri v. Fridkingreen
mo · 1991 · cited in 2 Missouri opinions naming this issue, 2005–2005
2 sentences

2005“The parole evidence rule bars extrinsic evidence, unless an integrated contract is ambiguous.” Royal Banks of Mo. v. Fridkin, 819 S.W.2d 359, 361 (Mo. banc 1991).

2005"The parole evidence rule bars extrinsic evidence, unless an integrated contract is ambiguous." Royal Banks of Mo. v. Fridkin, 819 S.W.2d 359, 361 (Mo. banc 1991).

22
Union Electric Co. v. Fundways, Ltd.green
moctapp · 1994 · cited in 1 Missouri opinions naming this issue, 2024–2024
1 sentence

2024Integration clauses “announce[] and demonstratef] the all inclusive-nature of the written instrument and furnish[] additional reason for applying the parole evidence rule.” Union Elec, Co. v. Fundways, Lid., 886 S.W.2d 169, 171 (Mo. App. E.D. 1994).

11
J.R. Waymire Co. v. Antares Corp.green
moctapp · 1998 · cited in 1 Missouri opinions naming this issue, 2016–2016
1 sentence

2016Waymire Co. v. Antares Corp., 975 S.W.2d 243, 247 (Mo.App.1998).

11
City of Gainesville v. Gillilandgreen
moctapp · 1986 · cited in 1 Missouri opinions naming this issue, 2001–2001
1 sentence

2001Appellant quotes from City of Gainesville v. Gilliland, 718 S.W.2d 553, 580 (Mo.App.1986), as authority for his argument that the court should set aside the deed creating the joint tenancy, stating: The mere absence of consideration is not sufficient to cancel the deed without some additional circumstances such as fraud.

11
Murphy v. Carrongreen
mo · 1976 · cited in 1 Missouri opinions naming this issue, 1993–1993
1 sentence

1993Our scope of review is defined in Murphy v. Carrón, 536 S.W.2d 30, 32 (Mo. banc 1976).

11
Willis v. Community Developers, Inc.green
moctapp · 1978 · cited in 1 Missouri opinions naming this issue, 1987–1987
1 sentence

1987Willis v. Community Developers, Inc., 563 S.W.2d 104, 107 (Mo.App., W.D.1978).

11
Harris v. Union Electric Co.green
moctapp · 1981 · cited in 1 Missouri opinions naming this issue, 1981–1981
1 sentence

1981Modine Manufacturing Co. v. Carlock, 510 S.W.2d 462 (Mo.1974); Fisher v. Miceli, 291 S.W.2d 845 (Mo.1956) and Harris v. Union Electric Co., 622 S.W.2d 239, 247 (Mo.App.1981).

11
Commerce Trust Co. v. Wattsgreen
mo · 1950 · cited in 1 Missouri opinions naming this issue, 1950–1950
1 sentence

1950See Commerce Trust Co. v. Watts, Mo.Sup., 231 S.W.2d 817 ; and Bank of Mountain View v. Winebrenner, 355 Mo. 79 , 195 S.W.2d 486 .

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (12)

CaseCitedYears
State v. Pickens green
moctapp · 2016
2 sentences

2022“The parole evidence rule prohibits use of oral evidence to contradict or change the terms of a written, unambiguous and complete contract absent fraud, common mistake, accident or erroneous omission.” Harms v. Harms, 496 S.W.3d 534 , 540 n.9 (Mo. App. 2016) (internal quotation marks and citation omitted).

2022“The rule prohibits evidence of contrary agreements made prior to or contemporaneously with the writing … [and] it is presumed that a written contract embodies the entire agreement of the parties[.]” Id.

12022–2022
Robson v. Diem green
moctapp · 2010
1 sentence

2011There, we held that although the parole evidence rule prohibits parties and those holding title in privity from a party from relying on extrinsic evidence to alter an unambiguous document, that rule does not apply to third parties challenging "the validity *275 of a seemingly unambiguous instrument.” Id. at 713-14 .

12011–2011
Warrenton Campus Shopping Center, Inc. v. Adolphus green
moctapp · 1990
1 sentence

2003“The parole evidence rule prohibits use of oral evidence to contradict or change the terms of a written, unambiguous and complete contract absent fraud, common mistake, accident or erroneous omission.” Warrenton Campus Shopping Ctr., Inc., 787 S.W.2d at 855 .

12003–2003
Fisher v. Miceli green
mo · 1956
1 sentence

1981Modine Manufacturing Co. v. Carlock, 510 S.W.2d 462 (Mo.1974); Fisher v. Miceli, 291 S.W.2d 845 (Mo.1956) and Harris v. Union Electric Co., 622 S.W.2d 239, 247 (Mo.App.1981).

11981–1981
Modine Manufacturing Company v. Carlock green
mo · 1974
1 sentence

1981Modine Manufacturing Co. v. Carlock, 510 S.W.2d 462 (Mo.1974); Fisher v. Miceli, 291 S.W.2d 845 (Mo.1956) and Harris v. Union Electric Co., 622 S.W.2d 239, 247 (Mo.App.1981).

11981–1981
South Side Plumbing Co. v. Tigges green
moctapp · 1975
2 sentences

1980South Side Plumbing Co. v. Tigges, 525 S.W.2d 583 (Mo.App.1975).

1980South Side Plumbing Co. v. Tigges, 525 S.W.2d 583 (Mo.App.1975).

11980–1980
Insurance Co. v. Mowry green
scotus · 1878
2 sentences

1962The court also quoted from the case of Insurance Co. v. Mowry, 96 U.S. 544, 1 . c. 547, 24 L.Ed. 674 : “The understanding of the parties as to the amount of the insurance, the conditions upon which it should be payable, and the premium to be paid, was there expressed, for the very purpose of avoiding any controversy or question respecting them.

1962The court also quoted from the case of Insurance Co. v. Mowry, 96 U.S. 544, 1 . c. 547, 24 L.Ed. 674 : “The understanding of the parties as to the amount of the insurance, the conditions upon which it should be payable, and the premium to be paid, was there expressed, for the very purpose of avoiding any controversy or question respecting them.

11962–1962
Baker v. Keet-Rountree Dry Goods Co. green
· 1928
2 sentences

1962In Baker v. Keet-Rountree Dry Goods Co., 318 Mo. 969 , 2 S.W.2d 733, 1 . c. 740, 3 S.W.2d 1003 , the court stated: “The rule that all previous negotiations are merged into the contract as finally written applies particularly to insurance contracts. 22 C.J. p. 1112.” The parole evidence rule was applied in the case of General Accident Fire and Life Insurance Co. v. Owen Bldg.

1962In Baker v. Keet-Rountree Dry Goods Co., 318 Mo. 969 , 2 S.W.2d 733, 1 . c. 740, 3 S.W.2d 1003 , the court stated: “The rule that all previous negotiations are merged into the contract as finally written applies particularly to insurance contracts. 22 C.J. p. 1112.” The parole evidence rule was applied in the case of General Accident Fire and Life Insurance Co. v. Owen Bldg.

11962–1962
Dickson v. Maddox neutral
· 1932
2 sentences

1962But, until thus corrected, the policy must be taken as expressing the final understanding of the assured and of the insurance company.” The defendant contends that the parole evidence rule does not apply in this case because oral testimony is admissible to show that by reason of mistake the written instrument does not express the true intention of the parties, and cites Employers Indemnity Corp. v. Garrett, 327 Mo. 874 , 38 S.W.2d 1049 , and Dickson v. Maddox, 330 Mo. 51 , 48 S.W.2d 873 .

1962But, until thus corrected, the policy must be taken as expressing the final understanding of the assured and of the insurance company.” The defendant contends that the parole evidence rule does not apply in this case because oral testimony is admissible to show that by reason of mistake the written instrument does not express the true intention of the parties, and cites Employers Indemnity Corp. v. Garrett, 327 Mo. 874 , 38 S.W.2d 1049 , and Dickson v. Maddox, 330 Mo. 51 , 48 S.W.2d 873 .

11962–1962
General Accident & Life Insurance v. Owen Building Co. green
moctapp · 1917
2 sentences

1962Co., 195 Mo. App. 371 , 192 S.W. 145 , on a set of facts almost identical with the situation in the *521 instant case.

1962Co., 195 Mo. App. 371 , 192 S.W. 145 , on a set of facts almost identical with the situation in the *521 instant case.

11962–1962
Employers Indemnity Corp. v. Garrett green
mo · 1931
2 sentences

1962But, until thus corrected, the policy must be taken as expressing the final understanding of the assured and of the insurance company.” The defendant contends that the parole evidence rule does not apply in this case because oral testimony is admissible to show that by reason of mistake the written instrument does not express the true intention of the parties, and cites Employers Indemnity Corp. v. Garrett, 327 Mo. 874 , 38 S.W.2d 1049 , and Dickson v. Maddox, 330 Mo. 51 , 48 S.W.2d 873 .

1962But, until thus corrected, the policy must be taken as expressing the final understanding of the assured and of the insurance company.” The defendant contends that the parole evidence rule does not apply in this case because oral testimony is admissible to show that by reason of mistake the written instrument does not express the true intention of the parties, and cites Employers Indemnity Corp. v. Garrett, 327 Mo. 874 , 38 S.W.2d 1049 , and Dickson v. Maddox, 330 Mo. 51 , 48 S.W.2d 873 .

11962–1962
Bank of Mountain View v. Winebrenner neutral
· 1946
2 sentences

1950See Commerce Trust Co. v. Watts, Mo.Sup., 231 S.W.2d 817 ; and Bank of Mountain View v. Winebrenner, 355 Mo. 79 , 195 S.W.2d 486 .

1950See Commerce Trust Co. v. Watts, Mo.Sup., 231 S.W.2d 817 ; and Bank of Mountain View v. Winebrenner, 355 Mo. 79 , 195 S.W.2d 486 .

11950–1950

Where else courts name it

TX 15 (1958–2018) MO 14 (1950–2024) CA 13 (1960–2020) PA 10 (1974–2019) IL 10 (1956–2012) OH 9 (1999–2011) LA 6 (1940–2015) TN 5 (1958–2016) NC 5 (1973–2018) MI 5 (1978–2024) NY 5 (1999–2025) AZ 4 (1967–2018) CT 3 (1983–1999) WI 3 (1982–2023) DE 3 (1963–1974) MA 3 (1961–2015) RI 3 (1987–2002) NJ 3 (1949–2021) CO 2 (1948–1976) HI 2 (2020–2024) VT 2 (1950–1966) IN 2 (2008–2010) ID 2 (2024–2024) ND 2 (2013–2014) WV 2 (1978–2010) WY 2 (1992–1993) NV 2 (1943–1969) GA 2 (1988–2012)

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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