merger clause (Michigan) · Go Syfert
← Michigan issues

merger clause in Michigan

46 Michigan opinions name it 2 courts 1894–2026 11 in the last five years

The cases below were cited by Michigan 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 (18)

CaseFollowedCited
UAW-GM Human Resource Center v. KSL Recreation Corp.green
michctapp · 1998 · cited in 20 Michigan opinions naming this issue, 1999–2026
2 sentences

2026That is, when a contract contains a valid integration clause, parol evidence generally is inadmissible, and “the only fraud that could vitiate the contract is fraud that would invalidate the merger clause itself, i.e., fraud relating to the merger clause or fraud that invalidates the entire contract including the merger clause.” Id. at 503 (quotation marks and citation omitted); see also Hamade v Sunoco Inc (R&M), 271 Mich App 145, 171 ; 721 NW2d 233 (2006) (Parol evidence may not be used to contradict the explicit terms of an integration clause that nullifies all prior and contemporaneous agr

2026Their only response to defendants’ merger argument was their brief assertion during the motion hearing that “[t]he merger does not apply when you’re alleging fraud,” and that plaintiffs were “alleging that that merger was fraudulently obtained.” “[W]hen a contract contains a valid merger clause, the only fraud that could vitiate the contract is fraud that would invalidate the merger clause itself, i.e., fraud relating to the merger clause or fraud that invalidates the entire contract including the merger clause.” UAW-GM Human Resource Ctr v KSL Recreation Corp, 228 Mich App 486, 503 ; 579 NW2d

820
Hamade v. Sunoco, Inc.green
michctapp · 2006 · cited in 7 Michigan opinions naming this issue, 2015–2026
2 sentences

2026That is, when a contract contains a valid integration clause, parol evidence generally is inadmissible, and “the only fraud that could vitiate the contract is fraud that would invalidate the merger clause itself, i.e., fraud relating to the merger clause or fraud that invalidates the entire contract including the merger clause.” Id. at 503 (quotation marks and citation omitted); see also Hamade v Sunoco Inc (R&M), 271 Mich App 145, 171 ; 721 NW2d 233 (2006) (Parol evidence may not be used to contradict the explicit terms of an integration clause that nullifies all prior and contemporaneous agr

2022See also Hanmade v Sunoco, Inc (R & M), 271 Mich App 145, 170 ; 721 NW2d 333 (2006) (determining that the plaintiffs’ fraud claims did not survive a merger clause because the allegedly fraudulent representations were nullified by the integration clause).

57
Star Insurance v. United Commercial Insurance Agency, Inc.green
mied · 2005 · cited in 2 Michigan opinions naming this issue, 2013–2015
2 sentences

2015However, in the context of an integration clause, which releases all antecedent claims, only certain types of fraud would vitiate the contract.” UAW-GM, 228 Mich App at 503 (citations omitted). “[W]hen a contract contains a valid merger clause, the only fraud that could vitiate the contract is fraud that would invalidate the merger clause itself, i.e., fraud relating to the merger clause or fraud that invalidates the entire contract including the merger clause.” Id. “ ‘There is an important distinction between (a) representations of fact made by one party to another to induce that party to ent

2013A merger clause can render reliance unjustified as to agreements, promises or understandings related to performances that are not included in the written agreement. [Star Ins Co v United Commercial Ins Agency, Inc, 392 F Supp 2d 927, 928-929 (ED Mich, 2005) (some emphasis omitted).] Plaintiffs allege that, although Zarb realized that they were particularly interested in the Robocolor Process, Zarb failed to inform plaintiffs that the process had been sold.

22
Goodspeed v. Nicholsgreen
mich · 1925 · cited in 4 Michigan opinions naming this issue, 1974–2015
2 sentences

2015“Under the merger doctrine, ‘a deed made in full execution of a contract for the sale of land is presumed to merge the provisions of a preceding contract pursuant to which it is made, including all prior negotiations and agreements leading up to the execution of the deed[.]”’ Johnson, 281 Mich App at 374-375 , quoting Goodspeed v Nichols, 231 Mich 308, 316 ; 204 NW 122 (1925).

2015“Under the merger doctrine, ‘a deed made in full execution of a contract for the sale of land is presumed to merge the provisions of a preceding contract pursuant to which it is made, including all prior negotiations and agreements leading up to the execution of the deed[.]”’ Johnson, 281 Mich App at 374-375 , quoting Goodspeed v Nichols, 231 Mich 308, 316 ; 204 NW 122 (1925).

14
Johnson Family Ltd. Partnership v. White Pine Wireless, LLCgreen
michctapp · 2008 · cited in 3 Michigan opinions naming this issue, 2015–2024
2 sentences

2024“Under the merger doctrine, a deed made in full execution of a contract for the sale of land is presumed to merge the provisions of a preceding contract pursuant to which it is made, including all prior negotiations and agreements leading up to execution of the deed . . . .” Johnson Family LP v White Pine Wireless, LLC, 281 Mich App 364, 374-375 ; 761 NW2d 353 (2008) (quotation marks and citation omitted; ellipsis in original).

2024“Under the merger doctrine, a deed made in full execution of a contract for the sale of land is presumed to merge the provisions of a preceding contract pursuant to which it is made, including all prior negotiations and agreements leading up to execution of the deed . . . .” Johnson Family LP v White Pine Wireless, LLC, 281 Mich App 364, 374-375 ; 761 NW2d 353 (2008) (quotation marks and citation omitted; ellipsis in original).

13
Custom Data Solutions, Inc v. Preferred Capital, Inc.green
michctapp · 2007 · cited in 2 Michigan opinions naming this issue, 2016–2026
2 sentences

2016Consequently, the merger clause in the equipment rental agreements is insufficient to prevent Plaintiff from introducing evidence of fraud, and Plaintiff’s motion for summary disposition to void the contract should be granted.’ [Custom Data, 274 Mich App at 244 .] On appeal, Norvergence argued that the plaintiff’s reliance on pre-contract representations was “patently unreasonable” because the representations were not contained within the written ERAs, which contained merger clauses.

2016During discovery, the plaintiff produced “uncontroverted evidence that the agreement . . . [was] the result of a fraudulent scheme by Norvergence to finance the services that Norvergence was promising to provide to Plaintiff and others,” which “invalidates the entire contract including the merger clause.” Id. at 244 (emphasis added).

12
Anderson v. Thompsongreen
mich · 1923 · cited in 1 Michigan opinions naming this issue, 2015–2015
2 sentences

2015A plain reading of the merger doctrine or rule clearly reflects no such requirement, as it simply provides that “when the holder of a real estate mortgage becomes the owner of the fee, the former estate is merged in the latter.” Anderson, 225 Mich at 159 ; see also Heritage Village, 305 Mich App at 105 .

2015Again, the merger doctrine is “subject to the exception that when it is to the interest of the mortgagee and is his intention to -6- keep the mortgage alive, there is no merger, unless the rights of the mortgagor or third persons are affected thereby.” Anderson, 225 Mich at 159 (emphasis added).

11
Reserve at Heritage Village Ass'n v. Warren Financial Acquisition, LLCgreen
michctapp · 2014 · cited in 1 Michigan opinions naming this issue, 2015–2015
2 sentences

2015A plain reading of the merger doctrine or rule clearly reflects no such requirement, as it simply provides that “when the holder of a real estate mortgage becomes the owner of the fee, the former estate is merged in the latter.” Anderson, 225 Mich at 159 ; see also Heritage Village, 305 Mich App at 105 .

2015A plain reading of the merger doctrine or rule clearly reflects no such requirement, as it simply provides that “when the holder of a real estate mortgage becomes the owner of the fee, the former estate is merged in the latter.” Anderson, 225 Mich at 159 ; see also Heritage Village, 305 Mich App at 105 .

11
Adair v. Adairgreen
mich · 1858 · cited in 1 Michigan opinions naming this issue, 2010–2010
1 sentence

2010As this Court recognized in 1858, [t]o hold that a party may reply to an action upon a written instrument, “It is true I made the contract, but it was not my agreement, and I did not intend to be bound by it,” would set the law of contracts all afloat, render the certainty of the law a fiction, and place the obligations of parties beyond judicial control. [Adair v Adair, 5 Mich 204, 209 (1858).] 3 As an additional reason for affirming the trial court, Romska noted that the “release contains an explicit merger clause that independently precludes resort to parol evidence” and that a contrary rul

11
Romska v. Oppergreen
michctapp · 1999 · cited in 1 Michigan opinions naming this issue, 2010–2010
2 sentences

2010As Romska explained, if “clear release language, coupled with a merger clause, does not afford protection against [having to defend against remaining claims], it is hard to understand how finality could ever be achieved through a negotiated release.” Id. at 518. 4 While the partial dissent in Romska would have permitted parol evidence on its theory that the defendant was a “stranger” to the release, it should be noted that the partial dissent did not find that the release contained any ambiguity, patent or latent.

2010As this Court recognized in 1858, [t]o hold that a party may reply to an action upon a written instrument, “It is true I made the contract, but it was not my agreement, and I did not intend to be bound by it,” would set the law of contracts all afloat, render the certainty of the law a fiction, and place the obligations of parties beyond judicial control. [Adair v Adair, 5 Mich 204, 209 (1858).] 3 As an additional reason for affirming the trial court, Romska noted that the “release contains an explicit merger clause that independently precludes resort to parol evidence” and that a contrary rul

11
Meridian Mutual Insurance v. Mason-Dixon Lines, Inc.green
michctapp · 2000 · cited in 1 Michigan opinions naming this issue, 2010–2010
2 sentences

2010See, e.g., Meridian Mut Ins Co v Mason-Dixon Lines, Inc (On Remand), 242 Mich App 645, 647 ; 620 NW2d 310 (2000); Collucci v Eklund, 240 Mich App 654, 658 ; 613 NW2d 402 (2000), lv den 463 Mich 934 (2000); Beck v McKinzie, unpublished opinion per curiam of the Court of Appeals, issued November 20, 2001 (Docket No. 223680); Batshon v Mar-Que Gen Contractors, Inc, 463 Mich 646 , 650 n 6; 624 NW2d 903 (2001); Samuel v Mitsubishi, unpublished opinion per curiam of the Court of Appeals, issued May 24, 2002 (Docket No. 229464), lv den 467 Mich 953 (2003); Ruppel v Carlson, unpublished opinion per cu

2010See, e.g., Meridian Mut Ins Co v Mason-Dixon Lines, Inc (On Remand), 242 Mich App 645, 647 ; 620 NW2d 310 (2000); Collucci v Eklund, 240 Mich App 654, 658 ; 613 NW2d 402 (2000), lv den 463 Mich 934 (2000); Beck v McKinzie, unpublished opinion per curiam of the Court of Appeals, issued November 20, 2001 (Docket No. 223680); Batshon v Mar-Que Gen Contractors, Inc, 463 Mich 646 , 650 n 6; 624 NW2d 903 (2001); Samuel v Mitsubishi, unpublished opinion per curiam of the Court of Appeals, issued May 24, 2002 (Docket No. 229464), lv den 467 Mich 953 (2003); Ruppel v Carlson, unpublished opinion per cu

11
Parsons v. Detroit & Mackinac Railway Co.green
mich · 1899 · cited in 1 Michigan opinions naming this issue, 2008–2008
2 sentences

2008See Clifton v Jackson Iron Co, 74 Mich 183 ; 41 NW 891 (1889), partially overruled on other grounds Blough v Steffens, 349 Mich 365 (1957); see also Parsons v Detroit & M R Co, 122 Mich 462 ; 81 NW 343 (1899) (noting that, absent evidence of mistake or fraud, a deed would control over a previous contract).

2008See Clifton v Jackson Iron Co, 74 Mich 183 ; 41 NW 891 (1889), partially overruled on other grounds Blough v Steffens, 349 Mich 365 (1957); see also Parsons v Detroit & M R Co, 122 Mich 462 ; 81 NW 343 (1899) (noting that, absent evidence of mistake or fraud, a deed would control over a previous contract).

11
Clifton v. Jackson Iron Co.green
mich · 1889 · cited in 1 Michigan opinions naming this issue, 2008–2008
2 sentences

2008See Clifton v Jackson Iron Co, 74 Mich 183 ; 41 NW 891 (1889), partially overruled on other grounds Blough v Steffens, 349 Mich 365 (1957); see also Parsons v Detroit & M R Co, 122 Mich 462 ; 81 NW 343 (1899) (noting that, absent evidence of mistake or fraud, a deed would control over a previous contract).

2008See Clifton v Jackson Iron Co, 74 Mich 183 ; 41 NW 891 (1889), partially overruled on other grounds Blough v Steffens, 349 Mich 365 (1957); see also Parsons v Detroit & M R Co, 122 Mich 462 ; 81 NW 343 (1899) (noting that, absent evidence of mistake or fraud, a deed would control over a previous contract).

11
Roy Travis Douglas, of the Estate of Ada Clayborn, Deceased v. United States Tobacco Companygreen
ca8 · 1982 · cited in 1 Michigan opinions naming this issue, 1999–1999
11
Gregory v. Wendellgreen
mich · 1879 · cited in 1 Michigan opinions naming this issue, 1998–1998
11
Clark v. Federal Land Bankgreen
michctapp · 1987 · cited in 1 Michigan opinions naming this issue, 1989–1989
11
People v. Richardsgreen
mich · 1849 · cited in 1 Michigan opinions naming this issue, 1982–1982
11
Arnold v. Masonic Country Clubgreen
mich · 1934 · cited in 1 Michigan opinions naming this issue, 1979–1979
11

Distinguished, questioned or overruled (1)

CaseNegativeCited
Thyroff v. Nationwide Mutual Insurancegreen
ny · 2007 · cited in 1 Michigan opinions naming this issue, 2020–2020
1 sentence

2020Characterizing the strict application of a merger requirement as “vestigial,” the Ninth Circuit declared: “Were it necessary to settle the issue once and for all, we would . . . hold that conversion is a remedy for the conversion of every species of personal property.” Id. (quotation marks and citation omitted).7 See also Thyroff, 8 NY3d at 292-293 (“[W]e believe that the tort of conversion must keep pace with the contemporary realities of widespread computer use.

11

Also cited on this issue (28)

CaseCitedYears
Barclae v. Zarb green
michctapp · 2013
2 sentences

2022If those purchase agreements contained a boilerplate merger clause,1 “the only fraud that could vitiate the contract is fraud that would invalidate the merger clause itself, i.e., fraud relating to the merger clause or fraud that invalidates the entire contract including the merger clause.” Barclae v Zarb, 300 Mich App 455, 480 ; 834 NW2d 100 (2013) (citation omitted).

2022If those purchase agreements contained a boilerplate merger clause,1 “the only fraud that could vitiate the contract is fraud that would invalidate the merger clause itself, i.e., fraud relating to the merger clause or fraud that invalidates the entire contract including the merger clause.” Barclae v Zarb, 300 Mich App 455, 480 ; 834 NW2d 100 (2013) (citation omitted).

42015–2022
P Katelyn Zwiker v. Lake Superior State University green
michctapp · 2022
2 sentences

2026That is, when a contract contains a valid integration clause, parol evidence generally is inadmissible, and “the only fraud that could vitiate the contract is fraud that would invalidate the merger clause itself, i.e., fraud relating to the merger clause or fraud that invalidates the entire contract including the merger clause.” Id. at 503 (quotation marks and citation omitted); see also Hamade v Sunoco Inc (R&M), 271 Mich App 145, 171 ; 721 NW2d 233 (2006) (Parol evidence may not be used to contradict the explicit terms of an integration clause that nullifies all prior and contemporaneous agr

2026That is, when a contract contains a valid integration clause, parol evidence generally is inadmissible, and “the only fraud that could vitiate the contract is fraud that would invalidate the merger clause itself, i.e., fraud relating to the merger clause or fraud that invalidates the entire contract including the merger clause.” Id. at 503 (quotation marks and citation omitted); see also Hamade v Sunoco Inc (R&M), 271 Mich App 145, 171 ; 721 NW2d 233 (2006) (Parol evidence may not be used to contradict the explicit terms of an integration clause that nullifies all prior and contemporaneous agr

22024–2026
Denha v. Jacob green
michctapp · 1989
2 sentences

2010Judge HOEKSTRA authored a partial concurrence and partial dissent. 18 Id. 19 Id. at 516 . 20 Id. at 516-517 . 21 Id. 9 The majority went on to reason that the settling parties likely included broad language in the release for the purpose of avoiding future legal burdens that could potentially arise out of lawsuits brought by the plaintiff against third parties.22 The majority cautioned that finality might never be truly achieved through a release if even unambiguous release language, coupled with a merger clause, cannot effectively preclude such future lawsuits.23 In contrast, the partial diss

2010Judge HOEKSTRA authored a partial concurrence and partial dissent. 18 Id. 19 Id. at 516 . 20 Id. at 516-517 . 21 Id. 9 The majority went on to reason that the settling parties likely included broad language in the release for the purpose of avoiding future legal burdens that could potentially arise out of lawsuits brought by the plaintiff against third parties.22 The majority cautioned that finality might never be truly achieved through a release if even unambiguous release language, coupled with a merger clause, cannot effectively preclude such future lawsuits.23 In contrast, the partial diss

21999–2010
Mueller v. Bankers Trust Co. green
mich · 1933
2 sentences

1974With respect to defendants’ claim of merger, the trial court found: "The court finds after having reviewed all the testimony taken in this case, the pleadings of the parties *320 hereto, and especially by application of the rules found in Goodspeed v Nichols, 231 Mich 308 [ 204 NW 122 (1925)]; Mueller v Bankers Trust Co, 262 Mich 53 [ 247 NW 103 (1933)], as a matter of law that the doctrine of merger does not apply in this case so as to relieve plaintiffs herein from the obligations set out under said paragraph 'L\ * * * "This court further finds as a matter of law that the deeds executed betw

1974With respect to defendants’ claim of merger, the trial court found: "The court finds after having reviewed all the testimony taken in this case, the pleadings of the parties *320 hereto, and especially by application of the rules found in Goodspeed v Nichols, 231 Mich 308 [ 204 NW 122 (1925)]; Mueller v Bankers Trust Co, 262 Mich 53 [ 247 NW 103 (1933)], as a matter of law that the doctrine of merger does not apply in this case so as to relieve plaintiffs herein from the obligations set out under said paragraph 'L\ * * * "This court further finds as a matter of law that the deeds executed betw

21974–2001
Chapdelaine v. Sochocki green
michctapp · 2001
2 sentences

2024In Chapdelaine v Sochocki, 247 Mich App 167, 172 ; 635 NW2d 339 (2001), this Court held that an easement provision in a purchase agreement could not be fulfilled “until after the deed was delivered and, therefore, was not fulfilled by the deed.” This Court explained that because the deed that the plaintiff delivered to the defendants “did not constitute full performance of the -9- easement provision in the purchase agreement, the doctrine of merger did not apply” to extinguish the plaintiff’s express easement reservation.

2024In Chapdelaine v Sochocki, 247 Mich App 167, 172 ; 635 NW2d 339 (2001), this Court held that an easement provision in a purchase agreement could not be fulfilled “until after the deed was delivered and, therefore, was not fulfilled by the deed.” This Court explained that because the deed that the plaintiff delivered to the defendants “did not constitute full performance of the -9- easement provision in the purchase agreement, the doctrine of merger did not apply” to extinguish the plaintiff’s express easement reservation.

12024–2024
Brachman v. Wheelock, Inc. green
mich · 1955
2 sentences

2023The merger rule “generally recogniz[es] that verbal understandings and negotiations are merged in a written agreement that is full and complete.” Brachman v Wheelock, Inc, 343 Mich 230, 235 ; 72 NW2d 246 (1955).

2023The merger rule “generally recogniz[es] that verbal understandings and negotiations are merged in a written agreement that is full and complete.” Brachman v Wheelock, Inc, 343 Mich 230, 235 ; 72 NW2d 246 (1955).

12023–2023
Kremen v. Cohen green
ca9 · 2003
1 sentence

2020Characterizing the strict application of a merger requirement as “vestigial,” the Ninth Circuit declared: “Were it necessary to settle the issue once and for all, we would . . . hold that conversion is a remedy for the conversion of every species of personal property.” Id. (quotation marks and citation omitted).7 See also Thyroff, 8 NY3d at 292-293 (“[W]e believe that the tort of conversion must keep pace with the contemporary realities of widespread computer use.

12020–2020
Dolese v. Bellows-Claude Neon Co. green
mich · 1932
2 sentences

2016Sturgis’s common-law argument centers on “the doctrine of merger.” Sturgis relies heavily on Dolese v Bellows-Claude Neon Co, 261 Mich 57 ; 245 NW 569 (1932), to support this argument.

2016Sturgis’s common-law argument centers on “the doctrine of merger.” Sturgis relies heavily on Dolese v Bellows-Claude Neon Co, 261 Mich 57 ; 245 NW 569 (1932), to support this argument.

12016–2016
Union Bank & Trust Co. v. Farmwald Development Corp. neutral
michctapp · 1989
2 sentences

2016Defendant suggests that the merger doctrine, whereby a mortgage is extinguished when the mortgagee obtains title to the property, Union Bank & Trust Co, NA v Farmwald Development Corp, 181 Mich App 538, 547 ; 450 NW2d 274 (1989), somehow bars the trial court from awarding attorney fees incurred after a deficiency judgment is entered.

2016Defendant suggests that the merger doctrine, whereby a mortgage is extinguished when the mortgagee obtains title to the property, Union Bank & Trust Co, NA v Farmwald Development Corp, 181 Mich App 538, 547 ; 450 NW2d 274 (1989), somehow bars the trial court from awarding attorney fees incurred after a deficiency judgment is entered.

12016–2016
First Nat. Bank of Utica v. Ramm neutral
mich · 1932
1 sentence

2015“When once extinguished it [was] gone forever.” First Nat’l Bank, 256 Mich at 577 .

12015–2015
Titan Insurance Company v. Hyten green
mich · 2012
1 sentence

2013Thus, when a contract contains a valid merger clause, the only fraud that could vitiate the contract is fraud that would invalidate the merger clause itself, i.e., fraud relating to the merger clause or fraud that invalidates the entire contract including the merger clause. [Id.] “Fraud in the procurement of the contract may be . . . grounds to retroactively avoid contractual obligations through traditional legal and equitable remedies such as cancellation, rescission, or reformation . ..Titan Ins, 491 Mich at 557-558 .

12013–2013
Collucci v. Eklund green
michctapp · 2000
2 sentences

2010See, e.g., Meridian Mut Ins Co v Mason-Dixon Lines, Inc (On Remand), 242 Mich App 645, 647 ; 620 NW2d 310 (2000); Collucci v Eklund, 240 Mich App 654, 658 ; 613 NW2d 402 (2000), lv den 463 Mich 934 (2000); Beck v McKinzie, unpublished opinion per curiam of the Court of Appeals, issued November 20, 2001 (Docket No. 223680); Batshon v Mar-Que Gen Contractors, Inc, 463 Mich 646 , 650 n 6; 624 NW2d 903 (2001); Samuel v Mitsubishi, unpublished opinion per curiam of the Court of Appeals, issued May 24, 2002 (Docket No. 229464), lv den 467 Mich 953 (2003); Ruppel v Carlson, unpublished opinion per cu

2010See, e.g., Meridian Mut Ins Co v Mason-Dixon Lines, Inc (On Remand), 242 Mich App 645, 647 ; 620 NW2d 310 (2000); Collucci v Eklund, 240 Mich App 654, 658 ; 613 NW2d 402 (2000), lv den 463 Mich 934 (2000); Beck v McKinzie, unpublished opinion per curiam of the Court of Appeals, issued November 20, 2001 (Docket No. 223680); Batshon v Mar-Que Gen Contractors, Inc, 463 Mich 646 , 650 n 6; 624 NW2d 903 (2001); Samuel v Mitsubishi, unpublished opinion per curiam of the Court of Appeals, issued May 24, 2002 (Docket No. 229464), lv den 467 Mich 953 (2003); Ruppel v Carlson, unpublished opinion per cu

12010–2010
Batshon v. Mar-Que General Contractors, Inc green
mich · 2001
2 sentences

2010See, e.g., Meridian Mut Ins Co v Mason-Dixon Lines, Inc (On Remand), 242 Mich App 645, 647 ; 620 NW2d 310 (2000); Collucci v Eklund, 240 Mich App 654, 658 ; 613 NW2d 402 (2000), lv den 463 Mich 934 (2000); Beck v McKinzie, unpublished opinion per curiam of the Court of Appeals, issued November 20, 2001 (Docket No. 223680); Batshon v Mar-Que Gen Contractors, Inc, 463 Mich 646 , 650 n 6; 624 NW2d 903 (2001); Samuel v Mitsubishi, unpublished opinion per curiam of the Court of Appeals, issued May 24, 2002 (Docket No. 229464), lv den 467 Mich 953 (2003); Ruppel v Carlson, unpublished opinion per cu

2010See, e.g., Meridian Mut Ins Co v Mason-Dixon Lines, Inc (On Remand), 242 Mich App 645, 647 ; 620 NW2d 310 (2000); Collucci v Eklund, 240 Mich App 654, 658 ; 613 NW2d 402 (2000), lv den 463 Mich 934 (2000); Beck v McKinzie, unpublished opinion per curiam of the Court of Appeals, issued November 20, 2001 (Docket No. 223680); Batshon v Mar-Que Gen Contractors, Inc, 463 Mich 646 , 650 n 6; 624 NW2d 903 (2001); Samuel v Mitsubishi, unpublished opinion per curiam of the Court of Appeals, issued May 24, 2002 (Docket No. 229464), lv den 467 Mich 953 (2003); Ruppel v Carlson, unpublished opinion per cu

12010–2010
Greenspan v. Rehberg green
michctapp · 1974
2 sentences

2008See Goodspeed v Nichols, 231 Mich 308, 315-316 ; 204 NW 122 (1925); Greenspan v Rehberg, 56 Mich App 310, 320 ; 224 NW2d 67 (1974).

2008See Goodspeed v Nichols, 231 Mich 308, 315-316 ; 204 NW 122 (1925); Greenspan v Rehberg, 56 Mich App 310, 320 ; 224 NW2d 67 (1974).

12008–2008
Blough v. Steffens green
mich · 1957
12008–2008
Panos v. Olsen & Associates Construction, Inc. green
utahctapp · 2005
2 sentences

2008See Czarobski v Lata, 227 Ill 2d 364, 371-373; 882 NE2d 536 (2008) (holding that mutual mistake is an exception to application of the merger doctrine and listing jurisdictions that have held the same); Panos v Olsen & Assoc Constr, Inc, 2005 Utah App 446, ¶ 14 ; 123 P3d 816 (2005) (stating that Utah recognizes four exceptions to appli *377 cation of the merger doctrine including “ ‘mutual mistake in the drafting of the final documents’ ”) (citation omitted); Providence Square Ass’n, Inc v Biancardi, 507 So 2d 1366, 1371 (Fla, 1987) (stating that the doctrine of merger “is inapplicable in an ac

2008See Czarobski v Lata, 227 Ill 2d 364, 371-373; 882 NE2d 536 (2008) (holding that mutual mistake is an exception to application of the merger doctrine and listing jurisdictions that have held the same); Panos v Olsen & Assoc Constr, Inc, 2005 Utah App 446, ¶ 14 ; 123 P3d 816 (2005) (stating that Utah recognizes four exceptions to appli *377 cation of the merger doctrine including “ ‘mutual mistake in the drafting of the final documents’ ”) (citation omitted); Providence Square Ass’n, Inc v Biancardi, 507 So 2d 1366, 1371 (Fla, 1987) (stating that the doctrine of merger “is inapplicable in an ac

12008–2008
Czarobski v. Lata green
ill · 2008
2 sentences

2008See Czarobski v Lata, 227 Ill 2d 364, 371-373; 882 NE2d 536 (2008) (holding that mutual mistake is an exception to application of the merger doctrine and listing jurisdictions that have held the same); Panos v Olsen & Assoc Constr, Inc, 2005 Utah App 446, ¶ 14 ; 123 P3d 816 (2005) (stating that Utah recognizes four exceptions to appli *377 cation of the merger doctrine including “ ‘mutual mistake in the drafting of the final documents’ ”) (citation omitted); Providence Square Ass’n, Inc v Biancardi, 507 So 2d 1366, 1371 (Fla, 1987) (stating that the doctrine of merger “is inapplicable in an ac

2008See Czarobski v Lata, 227 Ill 2d 364, 371-373; 882 NE2d 536 (2008) (holding that mutual mistake is an exception to application of the merger doctrine and listing jurisdictions that have held the same); Panos v Olsen & Assoc Constr, Inc, 2005 Utah App 446, ¶ 14 ; 123 P3d 816 (2005) (stating that Utah recognizes four exceptions to appli *377 cation of the merger doctrine including “ ‘mutual mistake in the drafting of the final documents’ ”) (citation omitted); Providence Square Ass’n, Inc v Biancardi, 507 So 2d 1366, 1371 (Fla, 1987) (stating that the doctrine of merger “is inapplicable in an ac

12008–2008
People v. Jones green
michctapp · 1995
12002–2002
People v. Wilson red
cal · 1969
12002–2002
Northern Securities Co. v. United States green
scotus · 1904
11998–1998
International Milling Co. v. Hachmeister, Inc. green
pa · 1955
11998–1998
People v. Causley green
mich · 1941
11997–1997
People v. Washington green
cal · 1965
11995–1995
Titus v. Cavalier green
mich · 1936
11989–1989
Kingery v. Ford Motor Co. green
michctapp · 1982
11988–1988
Roberts v. Marquette General Hospital neutral
michctapp · 1983
11988–1988
Rogers v. Colonial Federal Savings & Loan Ass'n yellow
mich · 1979
11988–1988
Dutton v. Ives neutral
mich · 1858
11894–1894

Statutes the citing opinions construe

MI § Mich. Comp. Laws § 600.2932 (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 486 (1823–2026) GA 294 (1933–2026) WA 275 (1927–2026) OH 253 (1896–2026) PA 236 (1889–2026) TX 224 (1888–2026) CA 169 (1919–2026) IL 100 (1900–2026) NC 75 (1920–2026) FL 72 (1938–2026) UT 70 (1945–2026) OR 63 (1977–2026) MA 63 (1921–2026) MD 60 (1962–2026) CO 59 (1895–2026) AL 58 (1872–2025) IA 54 (1883–2026) MO 50 (1894–2024) CT 49 (1979–2025) MI 46 (1894–2026) ID 42 (1959–2025) TN 39 (1917–2026) NJ 36 (1942–2025) KS 34 (1918–2026) VA 33 (1990–2025) DC 28 (1966–2026) HI 28 (1906–2026) MS 23 (1967–2023) KY 22 (1971–2025) MN 21 (1960–2017) SC 20 (1922–2025) NM 19 (1943–2024) AZ 19 (1927–2026) OK 18 (1930–2026) RI 18 (1989–2018) WV 16 (1987–2025) DE 15 (1930–2026) AR 14 (1916–2025) IN 14 (1878–2017) NH 13 (1988–2025) WI 13 (1901–2025) WY 13 (1951–2022) MT 13 (1980–2020) 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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