Parol Evidence in Washington: The Use of Extrinsic Evidence to Address the Integration and Interpretation of Documents

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Washington Law Review, Vol: 52, Issue: 4, Page: 923

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Olson, Arden J.
commentary description
Washington judicial treatment of these related concerns, the integration and interpretation of written contracts, constitutes the focus of this comment. Part One will distinguish integration from interpretation and highlight factors which bear on the choices between conflicting approaches to extrinsic evidence. Part Two will examine the rules governing the ascertainment of integration, by which courts decide whether the parties embodied their transaction in a written memorial, rendering it subject to the parol evidence rule. Part Three will analyze the analogous rules governing the extent to which a court interpreting the parties' language may look to the circumstances surrounding the document's execution. Finally, a suggestion will be made to improve Washington's approach to extrinsic evidence and to resolve current inconsistencies in the law.