201 Md. 115 (1952).

One-Sentence [run on :)]  Takeaway: Absent fraud, duress or mutual mistake, one having the capacity to understand a written document who reads and signs it, is bound by his signature in law; where there has been an integration of an agreement, those who executed it will not be allowed to place their own interpretation on what it means or was intended to mean.

Summary:  Defendant William G. Eurice & Bros., Inc. entered into a contract under which it promised to build a house for Mr. & Mrs. Ray according to certain specifications.  After Defendant breached the contract, Plaintiff sued.

In its defense, Defendant claimed that it had been under the mistaken belief that the contract was to be performed according to a set of specifications different from those set forth in the written contract.  The trial court ruled in favor of Defendant but the appellate court reversed that ruling.

The court first noted that the mistake, if any had been made at all, was unilateral:

If we assume the view as to mistake held by Judge Gontrum, in effect the mistake … was an unilateral one. It consisted, in the opinion of the Court, in the Eurice Corporation thinking it was assenting to its own specifications, while in form it was assenting to the Ray specifications. If there was such a mistake, the legal result the Court found to follow, we think does not follow.

The court then stated the general rule:

The law is clear, absent fraud, duress or mutual mistake, that one having the capacity to understand a written document who reads and signs it, or, without reading it or having it read to him, signs it, is bound by his signature in law, at least. An integrated agreement may not be varied by parol where there is no mutual mistake, nor may the parties place their own interpretation on its meaning or intended meaning.

Because “[n]either fraud nor duress are in the case,” the court held that the unilateral mistake as to the contract terms furnished no ground for rescission.

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