Hatley v. Stafford

284 Or. 523, 588 P.2d 603 (1978)



The parol evidence rule applies only to those aspects of a bargain that the parties intend to memorialize in the writing. The fact that a writing exists does not bring the rule into play if the parties do not intend the writing to embody their final agreement. Neither does the rule apply when the parties intend the writing to contain only part of their agreement.


Lessee rented a farm from the lessors. Later, the lessors took possession of the farm and cut the wheat crop. The lessee filed a trespass action against the lessors. In their answer, the lessors alleged that they were exercising their right to terminate the contract. The lessee replied that the written lease agreement was not the entire integrated agreement of the parties, and that they had orally agreed the buy out provision only applied for a short time after execution of the lease. The trial court allowed introduction of evidence concerning the oral agreement, and a verdict was rendered in favor of the lessee, which the lessors appealed. 


Was it proper to allow parol evidence?




The court held that nothing was contained in the writing with respect to the duration of the buy out provision. Therefore, the oral time limitation was consistent with the terms of the writing. In addition, there were a number of facts that could have led the trial court to conclude that it was natural for the parties to have omitted the time limitation on the buy out provision from the written lease. Thus, the Court held that there was sufficient evidence to justify the trial court's decision to admit the parol evidence.

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