Estate of Stanley Kauffmann v. Rochester Institute of Technology
United States District Court, Western District of New York
2018 WL 3731445 (2018)
Kauffmann (plaintiff, through his estate) signed and checked a box agreeing to a letter from his editor confirming his film reviews were and would continue to be "works made for hire" under copyright law, but after Rochester Institute of Technology (defendant) republished many reviews in a book, Kauffmann's estate sued for infringement, seeking to introduce extrinsic evidence — including a friend's testimony that Kauffmann believed he still owned the copyrights, evidence he'd licensed some reviews as though he owned them, and evidence he'd sign anything his editor presented regardless of understanding — to show he never actually agreed to give up his copyrights despite the letter's clear terms.
Whether the parol-evidence rule bars the introduction of any external evidence to contradict or modify the terms of a written contract unless there was fraud or a mutual mistake about the terms.