The Appellate Group

Schmith v. Schmit

Schmith v. Schmit, 2025 UT App 124 (Christiansen Forster, J.)

Civil/Civil Procedure

The Utah Court of Appeals held: 

  • The district court erred in considering extrinsic evidence to override the written contract’s integration clause. 
  • Practice tip: Extrinsic evidence is appropriately considered in the face of a clear integration clause where the contract is alleged to be a forgery, a joke, a sham, lacking in consideration, or where a contract is void for fraud, duress, mistake, or illegality. 

Read the full court opinion