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Trident Center v. Connecticut General Life Ins. Co. | 847 F.2d 564 (1988)

The parol evidence rule is a basic contract principle that excludes extrinsic evidence if offered to contradict a term of a completely or partially integrated written agreement. In Trident Center versus Connecticut General Life Insurance Company, the United States Court of Appeals for the Ninth Circuit considered the parol evidence rule as applied under California law.

In 1983, a life insurance company and two Los Angeles law firms formed a partnership called Trident Center to build an office building in West Los Angeles. Trident obtained a $56,500,000 loan from Connecticut General Life insurance Company, payable over fifteen years at 12.25 percent interest. By 1987, that 12.25 percent interest rate was much higher than the market rate and Trident wanted to refinance the loan. Connecticut General objected, contending that the loan agreement expressly prohibited prepayment of the loan for twelve years. Trident sued Connecticut General in state court, seeking a declaration that Trident could prepay the loan subject to a 10 percent prepayment fee. Connecticut General removed the case to federal court and filed a motion to dismiss. The district court granted that motion and also sanctioned Trident for filing a frivolous lawsuit. Trident appealed both the dismissal and the sanctions to the Ninth Circuit.

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