Lyons v. Beeman

The parol evidence rule, ORS 147.740 explains that “a binding, completely integrated, written agreement supersedes or discharges all agreements, written or oral, that were made before the completely integrated agreement, to the extent that the prior agreements are within the scope of the completely integrated agreement.”

Beeman appealed a judgment that awarded Lyons damages based on the jury’s verdict and from the supplemental judgments which awarded Lyons his attorney fees. Beeman assigned error to the trial court having denied a motion for directed verdict based on the claim that the parties had an unenforceable contract. Beeman argued that there was no evidence of an enforceable contract and the parol evidence rule barred evidence of the terms of the lease. The parol evidence rule, ORS 147.740 explains that “a binding, completely integrated, written agreement supersedes or discharges all agreements, written or oral, that were made before the completely integrated agreement, to the extent that the prior agreements are within the scope of the completely integrated agreement.” The Court held that the parol evidence rule did not apply to this case because the evidence Beeman wanted to exclude was from a previous pre-existing agreement and about modifications to the lease. Additionally, based on evidence from text messages and emails between the parties, there was sufficient evidence to establish that there was an existing obligation between the two and no new consideration was required. The jury had sufficient evidence to establish an enforceable agreement. Affirmed.