integration clause (Alabama) · Go Syfert
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integration clause in Alabama

8 Alabama opinions name it 2 courts 1985–2018 0 in the last five years

The cases below were cited by Alabama 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 (6)

CaseFollowedCited
Downs v. Wallacegreen
ala · 1993 · cited in 4 Alabama opinions naming this issue, 1993–2018
2 sentences

2018In Downs v. Wallace , [ 622 So.2d 337 (Ala. 1993),] this Court noted that such a holding is required: 'To hold otherwise is to encourage deliberate fraud.' 622 So.2d at 342 ." Environmental Sys., Inc. v. Rexham Corp. , 624 So.2d 1379 , 1383 (Ala. 1993) ; see also Downs v. Wallace, 622 So.2d 337 , 342 (Ala. 1993) (holding that "when the agreement has been induced by intentional fraud the mere presence of an integration clause in the written instrument does not, as a matter of law, insulate the guilty party").

2018In Downs v. Wallace , [ 622 So.2d 337 (Ala. 1993),] this Court noted that such a holding is required: 'To hold otherwise is to encourage deliberate fraud.' 622 So.2d at 342 ." Environmental Sys., Inc. v. Rexham Corp. , 624 So.2d 1379 , 1383 (Ala. 1993) ; see also Downs v. Wallace, 622 So.2d 337 , 342 (Ala. 1993) (holding that "when the agreement has been induced by intentional fraud the mere presence of an integration clause in the written instrument does not, as a matter of law, insulate the guilty party").

34
Environmental Systems v. Rexham Corp.green
ala · 1993 · cited in 4 Alabama opinions naming this issue, 2003–2018
2 sentences

2018In Downs v. Wallace , [ 622 So.2d 337 (Ala. 1993),] this Court noted that such a holding is required: 'To hold otherwise is to encourage deliberate fraud.' 622 So.2d at 342 ." Environmental Sys., Inc. v. Rexham Corp. , 624 So.2d 1379 , 1383 (Ala. 1993) ; see also Downs v. Wallace, 622 So.2d 337 , 342 (Ala. 1993) (holding that "when the agreement has been induced by intentional fraud the mere presence of an integration clause in the written instrument does not, as a matter of law, insulate the guilty party").

2018In Downs v. Wallace , [ 622 So.2d 337 (Ala. 1993),] this Court noted that such a holding is required: "To hold otherwise is to encourage deliberate fraud." 622 So.2d at 342.' " Environmental Sys., Inc. v. Rexham Corp. , 624 So.2d 1379 , 1383 (Ala. 1993) ; see also Downs v. Wallace , 622 So.2d 337 , 342 (Ala. 1993) (holding that 'when the agreement has been induced by intentional fraud the mere presence of an integration clause in the written instrument does not, as a matter of law, insulate the guilty party')." McCullough v. Allstate Prop. & Cas.

14
Crown Pontiac, Inc. v. McCarrellgreen
ala · 1997 · cited in 2 Alabama opinions naming this issue, 2003–2008
2 sentences

2008These clauses ‘are properly used to ensure that preliminary negotiations, whether oral or written[,] are either memorialized in the final contract or are not considered part of it.’ Crown Pontiac, Inc. v. McCarrell, 695 So.2d 615, 618 (Ala.1997).

2003These clauses "are properly used to ensure that preliminary negotiations, whether oral or written[,] are either memorialized in the final contract or are not considered part of it." Crown Pontiac, Inc. v. McCarrell , 695 So.2d 615 , 618 (Ala. 1997).

12
Universal Underwriters Insurance Co. v. Burrowsgreen
alacivapp · 1992 · cited in 1 Alabama opinions naming this issue, 2018–2018
1 sentence

2018In Downs v. Wallace , [ 622 So.2d 337 (Ala. 1993),] this Court noted that such a holding is required: "To hold otherwise is to encourage deliberate fraud." 622 So.2d at 342.' " Environmental Sys., Inc. v. Rexham Corp. , 624 So.2d 1379 , 1383 (Ala. 1993) ; see also Downs v. Wallace , 622 So.2d 337 , 342 (Ala. 1993) (holding that 'when the agreement has been induced by intentional fraud the mere presence of an integration clause in the written instrument does not, as a matter of law, insulate the guilty party')." McCullough v. Allstate Prop. & Cas.

11
Harbor Village Home Center, Inc. v. Thomasgreen
ala · 2003 · cited in 1 Alabama opinions naming this issue, 2008–2008
1 sentence

2008In Harbor Village Home Center, Inc. v. Thomas, 882 So.2d 811, 816 (Ala.2003), our supreme court explained merger clauses: “A merger clause, also known as an integration clause, ‘is a portion of a particular contract that restates the rationale of the parol evidence rule within the terms of the contract.’ Environmental Sys., Inc. v. Rexham Corp., 624 So.2d 1379, 1383 (Ala.1993).

11
Commercial Credit Co. v. Sealegreen
alactapp · 1942 · cited in 1 Alabama opinions naming this issue, 1985–1985
2 sentences

1985See, Commercial Credit Co. v. Seale , 30 Ala. App. 440 , 8 So.2d 199 (1942); 4 S. Williston, A Treatise on the Law of Contracts § 633 (3d ed. 1961).

1985See, Commercial Credit Co. v. Seale , 30 Ala. App. 440 , 8 So.2d 199 (1942); 4 S. Williston, A Treatise on the Law of Contracts § 633 (3d ed. 1961).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (8)

CaseCitedYears
Archambo v. Lawyers Title Ins. Corp. green
mich · 2002
2 sentences

2003Corp., 466 Mich. 402 , 414 n. 16, 646 N.W.2d 170 , 177 n. 16 (2002).

2003Corp., 466 Mich. 402 , 414 n. 16, 646 N.W.2d 170 , 177 n. 16 (2002).

12003–2003
Ramsay Health Care, Inc. v. Follmer green
ala · 1990
1 sentence

1993An integration clause, therefore, is also not applicable to exclude evidence relating to a fraud claim. 5 See Downs v. Wallace , supra; Harris v. M S Toyota , 575 So.2d 74 (Ala. 1991); Dixon v. SouthTrust Bank of Dothan, N.A. , 574 So.2d 706 , 708-09 (Ala. 1990); Ramsay Health Care, Inc. v. Follmer , 560 So.2d 746 , 748 (Ala. 1990); Curry Motor Co. v. Hasty , 505 So.2d 347 , 351 (Ala. 1987); Parker v. McGaha , 294 Ala. 702 , 707 , 321 So.2d 182 , 185 (1975) (noting that "[e]vidence of fraud is always admissible, even though there is a completely integrated writing"); Nelson Realty Co. v. Darli

11993–1993
Stanard Tilton Milling Co. v. Mixon green
ala · 1942
2 sentences

1993An integration clause, therefore, is also not applicable to exclude evidence relating to a fraud claim. 5 See Downs v. Wallace , supra; Harris v. M S Toyota , 575 So.2d 74 (Ala. 1991); Dixon v. SouthTrust Bank of Dothan, N.A. , 574 So.2d 706 , 708-09 (Ala. 1990); Ramsay Health Care, Inc. v. Follmer , 560 So.2d 746 , 748 (Ala. 1990); Curry Motor Co. v. Hasty , 505 So.2d 347 , 351 (Ala. 1987); Parker v. McGaha , 294 Ala. 702 , 707 , 321 So.2d 182 , 185 (1975) (noting that "[e]vidence of fraud is always admissible, even though there is a completely integrated writing"); Nelson Realty Co. v. Darli

1993An integration clause, therefore, is also not applicable to exclude evidence relating to a fraud claim. 5 See Downs v. Wallace , supra; Harris v. M S Toyota , 575 So.2d 74 (Ala. 1991); Dixon v. SouthTrust Bank of Dothan, N.A. , 574 So.2d 706 , 708-09 (Ala. 1990); Ramsay Health Care, Inc. v. Follmer , 560 So.2d 746 , 748 (Ala. 1990); Curry Motor Co. v. Hasty , 505 So.2d 347 , 351 (Ala. 1987); Parker v. McGaha , 294 Ala. 702 , 707 , 321 So.2d 182 , 185 (1975) (noting that "[e]vidence of fraud is always admissible, even though there is a completely integrated writing"); Nelson Realty Co. v. Darli

11993–1993
Curry Motor Co., Inc. v. Hasty green
ala · 1987
1 sentence

1993An integration clause, therefore, is also not applicable to exclude evidence relating to a fraud claim. 5 See Downs v. Wallace , supra; Harris v. M S Toyota , 575 So.2d 74 (Ala. 1991); Dixon v. SouthTrust Bank of Dothan, N.A. , 574 So.2d 706 , 708-09 (Ala. 1990); Ramsay Health Care, Inc. v. Follmer , 560 So.2d 746 , 748 (Ala. 1990); Curry Motor Co. v. Hasty , 505 So.2d 347 , 351 (Ala. 1987); Parker v. McGaha , 294 Ala. 702 , 707 , 321 So.2d 182 , 185 (1975) (noting that "[e]vidence of fraud is always admissible, even though there is a completely integrated writing"); Nelson Realty Co. v. Darli

11993–1993
Nelson Realty Co. v. Darling Shop of Birmingham, Inc. green
ala · 1957
2 sentences

1993An integration clause, therefore, is also not applicable to exclude evidence relating to a fraud claim. 5 See Downs v. Wallace , supra; Harris v. M S Toyota , 575 So.2d 74 (Ala. 1991); Dixon v. SouthTrust Bank of Dothan, N.A. , 574 So.2d 706 , 708-09 (Ala. 1990); Ramsay Health Care, Inc. v. Follmer , 560 So.2d 746 , 748 (Ala. 1990); Curry Motor Co. v. Hasty , 505 So.2d 347 , 351 (Ala. 1987); Parker v. McGaha , 294 Ala. 702 , 707 , 321 So.2d 182 , 185 (1975) (noting that "[e]vidence of fraud is always admissible, even though there is a completely integrated writing"); Nelson Realty Co. v. Darli

1993An integration clause, therefore, is also not applicable to exclude evidence relating to a fraud claim. 5 See Downs v. Wallace , supra; Harris v. M S Toyota , 575 So.2d 74 (Ala. 1991); Dixon v. SouthTrust Bank of Dothan, N.A. , 574 So.2d 706 , 708-09 (Ala. 1990); Ramsay Health Care, Inc. v. Follmer , 560 So.2d 746 , 748 (Ala. 1990); Curry Motor Co. v. Hasty , 505 So.2d 347 , 351 (Ala. 1987); Parker v. McGaha , 294 Ala. 702 , 707 , 321 So.2d 182 , 185 (1975) (noting that "[e]vidence of fraud is always admissible, even though there is a completely integrated writing"); Nelson Realty Co. v. Darli

11993–1993
Parker v. McGaha green
ala · 1975
2 sentences

1993An integration clause, therefore, is also not applicable to exclude evidence relating to a fraud claim. 5 See Downs v. Wallace , supra; Harris v. M S Toyota , 575 So.2d 74 (Ala. 1991); Dixon v. SouthTrust Bank of Dothan, N.A. , 574 So.2d 706 , 708-09 (Ala. 1990); Ramsay Health Care, Inc. v. Follmer , 560 So.2d 746 , 748 (Ala. 1990); Curry Motor Co. v. Hasty , 505 So.2d 347 , 351 (Ala. 1987); Parker v. McGaha , 294 Ala. 702 , 707 , 321 So.2d 182 , 185 (1975) (noting that "[e]vidence of fraud is always admissible, even though there is a completely integrated writing"); Nelson Realty Co. v. Darli

1993An integration clause, therefore, is also not applicable to exclude evidence relating to a fraud claim. 5 See Downs v. Wallace , supra; Harris v. M S Toyota , 575 So.2d 74 (Ala. 1991); Dixon v. SouthTrust Bank of Dothan, N.A. , 574 So.2d 706 , 708-09 (Ala. 1990); Ramsay Health Care, Inc. v. Follmer , 560 So.2d 746 , 748 (Ala. 1990); Curry Motor Co. v. Hasty , 505 So.2d 347 , 351 (Ala. 1987); Parker v. McGaha , 294 Ala. 702 , 707 , 321 So.2d 182 , 185 (1975) (noting that "[e]vidence of fraud is always admissible, even though there is a completely integrated writing"); Nelson Realty Co. v. Darli

11993–1993
Dixon v. Southtrust Bank of Dothan, N.A. green
ala · 1990
1 sentence

1993An integration clause, therefore, is also not applicable to exclude evidence relating to a fraud claim. 5 See Downs v. Wallace , supra; Harris v. M S Toyota , 575 So.2d 74 (Ala. 1991); Dixon v. SouthTrust Bank of Dothan, N.A. , 574 So.2d 706 , 708-09 (Ala. 1990); Ramsay Health Care, Inc. v. Follmer , 560 So.2d 746 , 748 (Ala. 1990); Curry Motor Co. v. Hasty , 505 So.2d 347 , 351 (Ala. 1987); Parker v. McGaha , 294 Ala. 702 , 707 , 321 So.2d 182 , 185 (1975) (noting that "[e]vidence of fraud is always admissible, even though there is a completely integrated writing"); Nelson Realty Co. v. Darli

11993–1993
Harris v. M & S TOYOTA, INC. green
ala · 1991
1 sentence

1993An integration clause, therefore, is also not applicable to exclude evidence relating to a fraud claim. 5 See Downs v. Wallace , supra; Harris v. M S Toyota , 575 So.2d 74 (Ala. 1991); Dixon v. SouthTrust Bank of Dothan, N.A. , 574 So.2d 706 , 708-09 (Ala. 1990); Ramsay Health Care, Inc. v. Follmer , 560 So.2d 746 , 748 (Ala. 1990); Curry Motor Co. v. Hasty , 505 So.2d 347 , 351 (Ala. 1987); Parker v. McGaha , 294 Ala. 702 , 707 , 321 So.2d 182 , 185 (1975) (noting that "[e]vidence of fraud is always admissible, even though there is a completely integrated writing"); Nelson Realty Co. v. Darli

11993–1993

Statutes the citing opinions construe

AL § Ala. Code § 12-2-7 (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

CA 103 (1951–2026) PA 103 (1974–2026) IL 60 (1981–2026) DE 56 (2003–2026) OH 46 (1995–2026) IN 37 (1986–2025) MI 37 (1998–2026) MA 31 (1979–2025) WA 28 (1969–2024) NY 26 (1982–2024) IA 21 (1981–2026) MD 20 (1949–2025) VA 20 (1964–2024) UT 20 (1988–2026) TX 20 (1992–2025) FL 16 (1959–2026) OR 15 (1978–2022) WI 11 (1943–2026) AZ 10 (1987–2026) NC 10 (1991–2026) MN 9 (1961–2015) DC 9 (1992–2026) AL 8 (1985–2018) ME 8 (1985–2019) CO 7 (1991–2025) TN 7 (2012–2026) SC 7 (1988–2011) NM 6 (1963–2024) MO 6 (1998–2023) NV 5 (1986–2021) MT 5 (1984–1994) NJ 4 (1990–2025) NH 4 (1982–2006) GA 4 (2005–2023) KS 4 (2006–2023) WY 4 (1978–2021) CT 4 (1997–2025) AK 2 (2003–2014) MS 2 (2000–2005) WV 2 (2010–2020) SD 2 (1959–2011)

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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