1 Wash. App. 874 - Diel v. Beekman’s Empirical Analysis
1970
Citation profile
3 federal appellate · 21 state decisions
How this case has been cited
Cited by 24 later decisions — most recently April 2012
3 federal appellate · 21 state decisions
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Relies on 62 Wash. 2d 195 - Balise v. Underwood · 52 Wash. 2d 129 - Duprey v. Donahoe · 75 Wash. 2d 241 - Black v. Evergreen Land Developers, Inc. · 40 Wash. 2d 238 - Donaldson v. Greenwood · 52 Wash. 2d 691 - Barber v. Rochester
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 24 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[T]he legal basis for the parol evidence rule is the theory of integration. A writing intended to supersede earlier and contemporaneous expressions is given that effect. This does not mean, however, that simply because there is a written agreement, other evidence will not be considered as a preliminary matter. . . . Thus, before the parol evidence rule can be applied, the court must hear all extrinsic evidence and determine if the parties intended that the written agreement be the complete integration.”
3 later decisions quote this exact passage““The use of such a name for this rule [parol evidence rule] has had unfortunate consequences, principally by distracting the attention from the real issues that are involved. These issues may be any one or more of the following: (1) Have the parties made a contract? (2) Is that contract void or voidable because of illegality, fraud, mistake, or any other reason? (3) Did the parties assent to a particular writing as the complete and accurate ‘integration’ of that contract? “In determining these issues, or any one of them, there is no ‘parol evidence rule’ to be applied. On these issues, no relevant evidence, whether parol or otherwise, is excluded. No written document is sufficient, standing alone, to determine any one of them, however long and detailed it may be, however formal, and however many may be the seals and signatures and assertions. No one of these issues can be determined by mere inspection of the written document.””
2 later decisions quote this exact passage“it is the court's duty to ascertain from all relevant, extrinsic evidence, either oral or written, whether the entire agreement has been incorporated in the writing or not. That is a question of fact.”
1 later decision quote this exact passagee.g. Lopez v. Reynoso
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.