Court of Appeal reverses $1 million judgment, holding that the Parol Evidence Rule bars a terminated insurance agent’s claim for fraud in the inducement

Dent v. Farmers Insurance Group of Companies (2007) 2007 Cal.App. Unpub. LEXIS 6013 (California Court of Appeal, Second Appellate District, Division Three) [unpublished]. Plaintiff became an insurance agent with GMSR’s client, an insurance carrier. Several years later the carrier terminated her when she did not meet the carrier’s expectations. She sued, claiming that various things she had been told – about how much she might earn, about her training, about her ability to control her own business and about not being terminated except for specific reasons – were false. The jury awarded her $500,000 in compensatory damages and $500,000 in punitive damages. On appeal, GMSR attorneys Bob Olson and Cindy Tobisman successfully argued that none of the claimed misrepresentations were supported by substantial evidence and, in particular, that the agent’s claim that she could not be terminated except for cause was barred by the parol evidence rule given the explicit without-cause termination provision in her agreement with the carrier.