Beware of effect that integration clauses have on prior employee agreements

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.

The appellate court affirmed the trial court’s denial of the employer’s request for summary judgment (dismissal without trial) in its favor, wherein the employer argued that the former employee’s employment application, which preceded his written employment agreement, contained a six-month contractual claim limitations period and, as a result, the claim was time-barred. Specifically, the former employee’s application contained a six-month claim limitation period, but his subsequent employment agreement did not. The employment agreement did contain “explicit integration and anti-supplementation provisions” and, accordingly, the application-based six-month claim limitation period was unenforceable.