Parol Evidence Rule

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Wiencek further argues that the trial court erred by considering “parol evidence to vary the effective date of the [B108 agreement] and to controvert the integration clause.” CHH, for its part, avers that the admission of parol evidence was proper because it was offered to determine whether the contract was effective. We hold that the circuit court did not violate the parole evidence rule because extrinsic evidence was not offered to add or modify any terms to the B108 agreement. Generally, parol or extrinsic evidence is inadmissible to vary the terms of an integrated contract. Foreman v. Melrod, 257 Md. 435, 441 (1970) (“‘All prior and contemporaneous negotiations are merged in the written instrument, which is treated as the exclusive …show more content…
v. Adam, 440 Md. 1, 7-8 (2014) (alteration in original) (quoting Gen. Motors Acceptance Corp. v. Daniels, 303 Md. 254, 261 (1985)). Were we to condone the introduction of extrinsic evidence to subvert the text of a completely integrated agreement, we would betray our commitment to the objective interpretation of contracts. Indeed, the parol evidence rule is a device that prevents the legal questions involving the interpretation of contracts from digressing into factual inquires into the subjective intent of the parties. Accordingly, we generally will not permit a litigant to vary the terms of a completely integrated agreement through the admission of extrinsic evidence. Although extrinsic evidence cannot be admitted to add of modify the terms of an integrated agreement, extrinsic evidence can be relied upon to serve other purposes. For example, “[a]ll courts generally agree that parol evidence is admissible when the written words are sufficiently ambiguous.” Calomiris v. Woods, 353 Md. 425, 433 (1999). Stated differently, parol evidence cannot be used to add or alter the terms of a completely integrated contract, but it can be used to define ambiguous terms. Likewise, “[i]t is well settled that the parol evidence rule does not prevent the introduction of parol evidence indicating that the written instrument was not to become effective as an instrument, until a prior condition or event had occurred.” Foreman, supra, 257 Md. at 442. “Parol evidence is admissible, therefore, to show that a writing never became effective as a contract or that it was void or voidable.” Tricat Indus., Inc. v. Harper, 131 Md. App. 89, 108 (2000). Stated

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