Yes, you can tell the judge about the lie. Lying to get someone to sign a contract is fraud, and there is a special exception to the normal contract rules for fraud. An old court case used to say you couldn't bring up a promise that contradicted the written contract. However, the California Supreme Court recently said that old rule was wrong because it let people use the contract as a 'shield' to get away with lying. It doesn't matter if the people involved are smart business experts; fraud is still fraud. The jury's job was to decide if Stinson and Bonjean were telling the truth and if it was reasonable for them to believe Payne's verbal promise, and the jury believed them.

Yes, people can tell the court about promises that aren't in the contract when they're saying they were tricked, even if those promises are different from what the contract says. We think the judge was right to let the jury hear about Payne's promises. The highest court in California recently decided that it's okay to do this, even if the promises are different from what's written in the contract. This is because we don't want people to use contracts to hide their lies. It doesn't matter if the people signing the contract are business experts or not. But just because the court can hear about these promises doesn't mean the person automatically wins their case. They still have to prove that it was reasonable for them to believe the promises, even though the contract said something different. In this case, there was enough evidence for the jury to decide that Stinson and Bonjean were reasonable to believe Payne's promises.

Yes, the fraud exception to the parol evidence rule allows evidence of a prior oral representation even if it directly contradicts the terms of a written agreement. Citing the recent Supreme Court decision in Riverisland, which overruled the long-standing Pendergrass rule, this court holds that parol evidence is admissible to prove a contract was induced by fraud. The Pendergrass rule, which barred evidence of a fraudulent promise directly at variance with the written terms, was an 'aberration' and inconsistent with the statutory fraud exception. The court rejected the defendants' argument that an exception should be made for sophisticated parties, finding no such limitation in Riverisland. The court reasoned that the parol evidence rule was never intended to be used as a shield for fraud. Therefore, the focus shifts from the admissibility of the evidence to whether the plaintiff can meet the heightened burden of proving the elements of fraud, particularly the reasonableness of their reliance on the oral promise despite the contradictory written terms.

Yes, parol evidence of fraudulent promises is admissible to prove fraud in the inducement of a contract, even if those promises directly contradict the terms of the written agreement. We affirm the trial court's decision to admit the parol evidence of Payne's alleged oral promises. The recent California Supreme Court decision in Riverisland Cold Storage, Inc. v. Fresno-Madera Production Credit Assn. (2013) overruled the previous limitation on the fraud exception to the parol evidence rule established in Bank of America etc. Assn. v. Pendergrass (1935). Riverisland held that the fraud exception in Code of Civil Procedure section 1856(g) allows parol evidence of fraudulent promises even when they contradict the written terms. This aligns with the statutory language and the long-standing policy that the parol evidence rule should not shield fraudulent conduct. We reject the argument that Riverisland should be limited to cases involving unsophisticated parties or contracts of adhesion, as the Supreme Court did not endorse such limitations. The admission of parol evidence does not create injustice, as the party claiming fraud must still prove reasonable reliance on the alleged misrepresentations. Here, substantial evidence supports the jury's finding that JCRI reasonably relied on Payne's oral assurances despite the contract language.

Julius Castle Restuarant, Inc. v. Payne

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