Under Pennsylvania law, fully integrated written contracts do not necessarily prevent an aggrieved party from successfully arguing that it was fraudulently induced into the contract by misrepresentations. If the contract at issue is fully integrated but lacks the “fraud-insulating” provisions needed to make it “integrated-plus,” then neither the gist of the action doctrine nor the parol evidence rule will bar a fraud claim against the party that allegedly made the pre-contractual misrepresentations.
At least that is what the U.S. Court of Appeals for the Third Circuit has held in three recent cases: Kelly v. Peerstar, Nos. 22-3031, 22-3087 (July 27, 2023); Battle Born Munitions v. Dicks Sporting Goods, No. 22-1005 (July 26, 2023) and SodexoMAGIC v. Drexel University, 24 F.4th 183 (2022).
