Four corners (law)

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The Four Corners Rule is a legal doctrine that courts use to determine the meaning of a written instrument such as a contract, will, or deed as represented solely by its textual content. The doctrine states that where there is an ambiguity of terms, the Court must rely on the written instrument solely and cannot consider extraneous evidence.

Contents

Contract interpretation

In contract interpretation, the Four Corners Rule refers to a common law doctrine dating back to old English courts that requires the court to resolve contractual disputes based on the words contained in the disputed contract. [1]

The four corners doctrine is similar to the parol evidence rule, which prohibits a contracting party from introducing evidence separate from the contract that would modify the contract in contravention of its written terms. [2] However, the Four Corners Doctrine prohibits a party from introducing evidence to interpret an unambiguous term.

The doctrine requires a court to discern what the contracting parties intended by using the whole document; no cherry picking. Most commercial contracts contain a clause entitled either "Merger", "Integration", or "Entire Agreement". In this clause, there would usually be language indicating that the parties' understanding of the other provisions of the contract are contained within the four corners of the same. Many modern contracts have taken it further to state that the entire agreement is contained within the agreement and that the agreement supersedes all prior understandings.

In some jurisdictions, including the US, the rule is controversial, and courts apply it with different degrees of force. [3]

Examples

An integration clause (merger clause) can express that the agreement is complete and fully integrated.

Case law

The following is an incomplete list of examples where courts used the Four Corners Doctrine while interpreting the disputed-document:

  1. From the four corners of the document: as derived from the text of the agreement itself, without relying upon other resources or witnesses.
    • "Absent ambiguity, the parties’ intentions must be discerned from the four corners of the document, and extrinsic evidence may not be considered." [4]
    • "Construction of a deed is a matter of law, and the intention of the parties is to be gathered from the four corners of the instrument." [5]
  2. Looking at the four corners of the will: examining and analyzing the will.
    • "It is evident to us, from looking at the four corners of the will, ..." [6]
  3. Determining whether to suppress evidence recovered and whether it was covered in the warrant.
    • "This Court has interpreted the above constitutional and statutory provisions of this State to mean just what they clearly state, and by doing so has characterized its interpretation by calling it the "four corners" rule or doctrine of law." [7]
    • "We granted defendant's application for certiorari, 600 So. 2d 617 (La.1992), primarily to consider the rulings of the lower courts in the light of the "four corners" doctrine pronounced by this court in State v. Wells, 253 La. 925, 221 So. 2d 50 (1969)." [8]
  4. Deed interpretation.
    • "This case involves construction of a deed through which a mineral interest was conveyed. The language within the deed's "four corners" was construed by the chancery court as unambiguous, and this Court affirms." [9]

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References

  1. ↑ Garner, Bryan A., ed. (2009). Black's law dictionary (9th ed.). St. Paul, MN: West. p. 728. ISBN   978-0314199492.
  2. ↑ Garner, Bryan A., ed. (2009). Black's law dictionary (9th ed.). St. Paul, MN: West. p. 1227. ISBN   978-0314199492.
  3. ↑ Silverstein, Joshua M. (2021). "The Contract Interpretation Policy Debate: A Primer". Stanford Journal of Law, Business & Finance. 26: 222.
  4. ↑ KY Supreme Court 2007-CA-000498
  5. ↑ KY Supreme Court 1995-CA-001813
  6. ↑ KY Supreme Court 1996-CA-000833
  7. ↑ Adkins v. State, 717 S.W.2d 363 (1986) Texas
  8. ↑ State v. Barrilleaux, 620 So. 2d 1317 (1993) Louisiana
  9. ↑ Pursue Energy Corp. v. Perkins, 558 So. 2d 349 (1990) Mississippi
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