Federal Deposit Insurance Corp. v. Hadid
Fourth Circuit
947 F.2d 1153 (1991)
The National Bank of Washington restructured two loans in exchange for Mohammed Hadid's (defendant) personal guarantees, memorialized in two written renewal and extension agreements, one of which was secured by a pledge of stock in McDowell Enterprises, Inc. Hadid, a sophisticated businessman represented by counsel, argued that he and the bank had also reached an oral side agreement giving him control over the McDowell stock or voiding his guarantees, and a jury agreed with him. The district court granted the bank's motion for judgment notwithstanding the verdict and entered judgment against Hadid for the notes plus attorney's fees; after the bank failed, the FDIC (plaintiff) was substituted in as successor, and Hadid appealed.
Whether a completely integrated written loan agreement between sophisticated, represented parties supersedes an alleged prior oral agreement on the same subject matter.