Poeppel v. Lester

827 N.W.2d 580 (2013)

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Poeppel v. Lester

South Dakota Supreme Court
827 N.W.2d 580 (2013)

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  • Written by Sean Carroll, JD
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Facts

Rob Poeppel (plaintiff) signed a contract with Lucas Lester (defendant), agreeing to sell his 25 percent voting interest in Coldwell Banker Lewis-Kirkeby-Hall Real Estate. The contract contained both parties’ acknowledgement that Poeppel had disclosed to Lester certain financial information about Coldwell. Lester did not attend the closing and did not pay the agreed-upon sale price. Poeppel sued Lester for breach of contract. Lester claimed that the contract was fraudulently signed because Poeppel had not provided the financial information about Coldwell. Specifically, Lester sought to introduce evidence that Poeppel stated that he could not disclose the information until after the execution of the contract. The trial court found that the contract was unambiguous with regard to whether the disclosure occurred and that the parol evidence rule barred the introduction of any evidence about the lack of disclosure of the financial documents. Lester appealed, arguing that the trial court’s evidentiary ruling was in error.

Rule of Law

Issue

Holding and Reasoning (Wilbur, J.)

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Casebooks

Contracts

Key Terms

  • Parol-Evidence RuleA general rule that prohibits the introduction into a court of law of any written or oral evidence to vary or contradict the unambiguous terms of an integrated agreement.
  • Fraud in the InducementFraud in which a person uses deceit or trickery to persuade another person to act in a certain way. Fraud in the inducement can result in a party signing a contract due to being misled about material terms. In criminal law, fraud in the inducement can occur if a perpetrator tricks a victim into consenting to what the victim knows is sexual intercourse, such as a doctor telling a patient that intercourse with the doctor is medically necessary.
  • Integrated AgreementA written contract that contains the entire understanding and agreement of the parties regarding all contract terms. Whether a writing is integrated and reflects the final agreement of the parties depends on the intent of the parties as determined from all the documents employed, the circumstances surrounding the execution of the documents, and the subsequent conduct of the parties.

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