Abstract
In Trident Center v. Connecticut General Life Insurance Co., the United States Court of Appeals for the Ninth Circuit held that a party to a completely integrated and unambiguous contract always may introduce extrinsic evidence to show the party's actual intent. If the evidence uncovers a latent ambiguity previously unnoticed in the written contract, then both parties may introduce additional extrinsic evidence to ascertain the actual intent of the parties. The Trident Center decision perpetuates the continuing demise of the parol evidence rule in California, originating with Pacific Gas & Electric Co. v. G.W. Thomas Drayage & Rigging Co. Essentially, Trident Center contributes to the parol evidence rule's circumvention. The Trident Center decision encourages a disgruntled party merely to claim that neither party meant what the contract's written terms actually state. Consequently, a party always may introduce at least some extrinsic evidence regarding the written contract.
Recommended Citation
Devashrayee, Jeffery J.
(1989)
"Trident Center v. Connecticut General Life Insurance Co.: The Continuing Demise of the California Parol Evidence Rule,"
Utah Law Review: Vol. 1989:
No.
4, Article 6.
Available at:
https://dc.law.utah.edu/ulr/vol1989/iss4/6