Beware of effect that integration clauses have on prior employee agreements

March 2026 employment law letter

Authors:

A recent Michigan Court of Appeals decision offers an important lesson for employers about how written employment documents interact—especially when there is an integration clause in an employment contract.

Facts

On February 17, 2026, the Michigan Court of Appeals held that when an employment agreement unambiguously states that “it is the parties’ entire agreement and prohibits supplementation except by a specified written modification, a limitations clause contained only in a separate employment application is not part of the contract” and, thus, cannot be used to bar the former employee’s claim for breach of the contract.

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