Sound Techniques, Inc. v. Hoffman
Massachusetts Appeals Court
737 N.E.2d 920 (2000)
Sound Techniques (plaintiff) leased second-floor space for a recording studio from Barry Hoffman (defendant), after Hoffman's leasing agent told Sound that the first-floor bar's ongoing expansion would only add dining space with background music, when the expansion actually included an upgraded sound system and dance floor; the signed lease contained a clause disclaiming reliance on any representations outside the agreement. After the noisy expansion disrupted Sound's recording business, Sound sued for breach of contract, fraud, and negligent misrepresentation, and the jury awarded judgment on the negligent-misrepresentation claim; Hoffman appealed.
Whether, under contract law, the parol-evidence rule prohibits the introduction of negligent misrepresentations into evidence for the purpose of contradicting the terms of a fully integrated agreement.