Seventh Circuit Permits Parol Evidence to Prove Fraud in the Inducement Despite Lack of Fraud in Integration Clause


In this week's post, we take a look at the recent Seventh Circuit case Judson Atkinson Candies, Inc. v. Kenray Associates, Inc. that held that parol evidence could be used to prove fraud in the inducement of a contract – a settlement agreement and covenant not to execute – even though the contract contained an integration clause. The decision reversed a trial court decision holding that parol evidence could only be used to show that the integration clause itself was the product of fraud.

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