The Parol Evidence Rule. Glenn Grove bought a 1936 Pontiac from Bernard Stanfield. Stanfield signed the certificate of title, which stated that the car was sold for $1,000. No other terms of sale were mentioned in the certificate, and none were

Question

incorporated by reference. Three years later, Stanfield filed a suit against Grove in a Missouri state court, claiming that Grove still owed $9,000 on the price of the car. At the trial, Stanfield testified that he and Grove had an oral agreement by which Grove was to pay $1,000 for the "title document" and $9,000 for the actual car. The court entered a judgment in Stanfield's favor. What will happen on appeal? Explain.

Answer 1

The parol evidence rule
The state intermediate appellate court held that Grove's payment of $1,000 to Stanfield fully discharged his obligation. The court reversed the lower court's judgment and entered a judgment for Grove. The appellate court stated that "[t]he title document is a legally sufficient contractual instrument, in that it names the parties thereto, recites the terms of each party's performance in clear language, and is signed by the party who challenges its facial meaning." The court reasoned that Stanfield "neither alleged nor adduced proof of fraud, mistake, duress, mental incapacity or unjust enrichment, so that none of the exceptions which might have made parol evidence admissible are present." The court concluded therefore that the trial court erred in admitting Stanfield's testimony.