Utah Court of Appeals reverses trial court, bars oral agreements where written contracts say they are entire deal

SALT LAKE CITY — The Utah Court of Appeals on Aug. 14, 2025 reversed a Salt Lake District Court ruling in a property dispute between Arnold J. Schmit (the appellant) and his nephew, Joshua Schmith (the appellee), holding that two written documents were integrated contracts and that the trial court improperly considered extrinsic oral agreements to conclude no lawful contract existed.

The appellate court said the two writings—dated 2013 and 2018—each contained an integration clause stating they were "the entire agreement between the parties," and that, absent an asserted invalidating cause such as fraud, forgery, duress, or mistake, the parol-evidence rule bars use of prior or contemporaneous oral statements to vary or add to the written terms.

Judge Michele M. Christiansen Forster, writing for the three-judge panel that included Judges Ryan M. Harris and Ryan D. Tenney, explained the court's holding: "in the face of a clear integration clause, extrinsic evidence of a separate oral agreement is not admissible on the question of integration." The opinion continued, "We agree with Uncle, and we reverse and remand the case for further proceedings."

Why it matters: The decision reaffirms Utah precedent limiting courts’ reliance on…