Employment application limitations provision; A subsequent employment agreement containing explicit integration & anti-supplementation provisions; Whether the application & employment agreement must be read together as a single contract; Effect of an express integration clause; Distinguishing Wyandotte Elec Supply Co v Electrical Tech Sys, Inc, Cutler v Spens, & Gray v Yatooma (Unpub); Whether the application’s limitations provision was inconsistent with the employment agreement; The parol-evidence rule

The court held that when an employment agreement unambiguously states “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 cannot be used to bar a claim for breach of the contract. Thus, it affirmed the trial court’s denial of defendants’ summary disposition motion. Plaintiff’s application contained a shortened six-month limitations period but his subsequent employment agreement did not. It did contain “explicit integration and anti-supplementation provisions.” Defendants’ argument that the documents “must be read together as a single contract” failed because it disregarded the employment agreement’s plain language. Reading the documents “together as a single contract would nullify” the employment agreement’s integration and modification provisions. The court also rejected their second argument, “that even if the writings are separate, the application’s limitations provision is not inconsistent with the employment agreement and therefore may be applied without violating the parol-evidence rule.” This misunderstood “both the parol-evidence rule and the role of an integration clause. The employment agreement is not silent on whether additional employment terms may be imported from outside writings; it expressly prohibits supplementation.” As to the assertion that the limitations period was “not a term of plaintiff’s employment, but merely a term of his application for employment[,]” the court noted that a “contractual provision that governs an employee’s ability to bring claims arising from his employment or termination regulates the employment relationship itself” and fell within the integration clause’s scope. The court held that the employment agreement was “a fully integrated contract that expressly supersedes prior employment agreements and prohibits supplementation by extraneous writings absent a signed written modification expressly referencing the agreement.” As the application’s limitations period was not “incorporated into the employment agreement in the manner the agreement requires, it” was not a term of the employment contract and could not “bar plaintiff’s breach-of-contract claim.”