Mitchill v. Lath

• In the early 1900s, people chilled their food in blocks of ice in lieu of refrigerators.
• Lath = farm owner
• Lunn = owner of land where Lath's ice house was located = owner of land across from Lath (farmer)
• Mitchill = buyer of Lath's farm = she considered the ice house an eyesore
• Lath promised to remove the ice house if Mitchill bought to farm
• Mitchill, through her husband, purchased the farm from Lath
• The real estate sales contract between Mitchill & Lath didn't mention the ice house
• Lath refused to remove the ice house

• Mitchill sued Lath for breach of contract for not removing the ice house in New York state court.
• Mitchill won in the trial court.
• The Appellate Divison in New York affirmed that Lath's oral promise to remove the ice house was part of the sales contract.

Under the parol evidence rule, can a fully integrated written contract be supplemented through evidence of a prior oral promise that's integral to the contract's subject matter?

No. If a written contract is fully integrated, then the parties can't change or add to its terms by introducing evidence of prior or contemporaneous communications integral to the contract.

Mitchill may not introduce evidence of Lath's oral promise to remove the ice house.

Reversed

Justice Andrews: In this case, the contract was extremely detailed. If Lath's removing of the icebox was a condition for Mitchill's purchase of the farm, one would expect the removal to be specified in the contract.

Justice Andrews: Lath's oral promise to remove the ice house may not be considered part of the contract.