Judson Atkinson Candies, Inc. v. Kenray Associates, Inc.

Federal 7th Circuit Court
Civil Court
Settlement
Citation
Case Number: 
Nos. 12-1035 & 12-1036 Cons.
Decision Date: 
June 11, 2013
Federal District: 
S.D. Ind., New Albany Div.
Holding: 
Reversed and remanded
Dist. Ct. erred in denying plaintiff’s motion to set aside on grounds of fraudulent inducement covenant contained in settlement agreement not to execute judgment in plaintiff’s favor in exchange for defendant’s assignment of right to sue third-party in insurance claim dispute, where settlement contained integration clause. Under Indiana law, Dist. Ct. improperly believed that mere existence of integration clause required plaintiff to show fraudulent inducement with respect to integration clause, rather than fraudulent inducement with respect to agreement as whole, before plaintiff could use parol evidence to vary terms of settlement agreement. On remand, Dist. Ct. must consider evidence as to whether parties actually intended integration clause to prohibit Dist. Ct. from doing anything other than to enforce covenant as written.