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Contracts Keyed to Burton
Riverisland Cold Storage, Inc. v. Fresno-Madera Production Credit Association
Citation:55 Cal. 4th 1169, 291 P.3d 316, 151 Cal. Rptr.3d 93
Lance and Pamela Workmans (collectively “the Workmans”) (plaintiffs) failed to make their loan payments on time. The Workmans restructured their $776,380.24 debt with Fresno-Madera Production Credit Association (hereinafter “Fresno-Madera”) (defendant) into a new agreement. Allegedly, two weeks before the new agreement was signed, Fresno-Madera’s vice president promised the Workmans that he would extend the loan for two years in exchange for additional collateral consisting solely of two ranches. The Workmans failed to make timely payments under the new agreement, and Fresno-Madera initiated foreclosure proceedings on the Workmans’ properties. At trial, the Workmans argued that the vice president’s representations were admissible evidence under the fraud exception to the parol evidence rule. The trial court disagreed. Under the reasoning of Bank of America etc. Association v. Pendergrass, the trial court concluded that the fraud exception did not allow parol evidence of promises that contradicted the terms of the written agreement. The appellate court reversed.
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