Pl - Yocca
Df - Pittsburgh Steelers Sports
The licensees received an SBL brochure and thereafter entered into an
SBL agreement to buy season tickets at the franchise's new stadium.
However, the licensees' assigned seats allegedly varied from the
diagram that they had been given with the SBL brochure.
The licensees filed a class action, alleging that the franchise
breached its contract, as well as claims for fraud, negligent
misrepresentation, and for declaratory relief.
The trial court sustained the franchise's preliminary
objections and dismissed the entire complaint.
On appeal, the commonwealth court reversed dismissal as to the
breach of contract, UPTCPL violation, and declaratory relief claims, and
further review was sought.
The Supreme Court held that the parol evidence rule barred any
consideration of the SBL brochure, as that document was similar to an
Initial SBL Brochure for new stadium seats what would give an
individual the right to be considered for an assigned see.
Club I seats between 20 yard line.
Section D, E, F were the same section sizes.
August 1999 produced a new diagram that varied from the earlier
diagram. The Club I seats were between the 10 yard lines, and section
D, E and F were not the same size.
Oct 1999 received the actual agreement
This Agreement contains the entire
agreement of the parties with respect to the matters provided for
herein and shall supersede
any representations or agreements previously made or entered into
by the parties hereto. No modification
hereto shall be enforceable unless in writing,
signed by both parties.
Parol Evidence Rule
Where the parties, without any fraud or mistake, have deliberately put
their engagements in writing, the law declares the writing to be not
only the best, but the only, evidence
of their agreement. All preliminary negotiations, conversations
and verbal agreements are merged in and
superseded by the subsequent written contract . . . and unless
fraud, accident or mistake be averred,
the writing constitutes the agreement between the parties, and
its terms and agreements cannot be added to nor subtracted from by parol
An integration clause which states that a writing is
meant to represent the parties' entire
agreement is also a clear sign that the writing is meant to be
just that and thereby expresses all of the parties' negotiations,
conversations, and agreements made prior to its execution.
Exception to Parol
Term was omitted.
Parties contract is
Evidence of the SBL Brochure diagrams must be admitted to describe and
define the seating section assignments referred to in the SBL Agreement.
The Licensee was assigned SBL seats was ambiguous because
it simply stated the section and failed to describe where that section
was located in the stadium.
Reasoning & Holding
By sending in their applications with the initial non-refundable
payment, Appellees simply secured their
right to be considered for assigned seats and the
to receive a subsequent offer to purchase SBLs for
The SBL agreement contained a diagram of all the set locations and
represented the parties entire
contract with respect to the sale of SBLs and that
the parol evidence rule bars the admission of
any previous agreements.