Day v. American Seafoods Co., 557 F.3d 1056 (9th Cir. 2009)

Jesse Day entered into a contract to work for American Seafoods Co. for one fishing voyage. In this lawsuit, Day sought payment for “unearned wages” for a period of time longer than the single voyage and contended that extrinsic evidence would establish an oral understanding for a longer period. The district court declined to admit parol evidence on the question, and the Ninth Circuit affirmed, holding that “on the basis of the explicit contractual language and the integration clause, the district court [correctly] held that Day could not offer extrinsic evidence to rebut the unambiguous duration agreed upon in the contract.”