Written > Oral

Texas law repeatedly reminds that the terms of written agreements usually supersede earlier oral representations, and Bank of America v. Haddad is the latest such reminder.

During 2018 negotiations for a new revolving line of credit, a bank’s relationship manager “repeatedly stated that ‘the new loan would not need a personal guaranty’ from Haddad,” and in an August 2018 email stated the guaranty language “can [be] remove[d].”

But more than seven months later, Haddad signed the actual loan documents without reading them. The final loan agreement listed a “Guaranty signed by Kevin T Haddad” as a required precondition to credit and contained an integration clause providing that the agreement “and any related security or other agreements required by this Agreement constitute the entire agreement” and “supersede all previous negotiations, communications, discussions and correspondence concerning the subject matter hereof.” Haddad separately signed a document titled “CONTINUING AND UNCONDITIONAL GUARANTY” listing him as “GUARANTOR.”

Accordingly, the Fifth Circuit affirmed summary judgment for the bank. No. 25-11330 (Oct. 9, 2026, unpublished),