as a matter of law to rely on parol representations or promises within the scope of the contract made prior to its execution.” But Michigan courts do not take the point so far. For instance, in Archambo v. Lawyers Title Ins. Corp., 466 Mich. 402, 646 N.W.2d 170 (2002), the Michigan Supreme Count held that although “an integration clause nullifies all antecedent agreements,” that rule is “[s]ubject ... to evidence of certain kinds of fraud (or other grounds sufficient to set aside a contract) and for the rare situation when the written document is obviously incomplete on its face.” Id. at 413, 414 n. 15, 646 N.W.2d at 177 & n. 15 (internal quotations and citations omitted); see also UAW-GM Human Resource Center v. KSL Recreation Corp., 228 Mich.App. 486, 503, 579 N.W.2d 411, 419 (1998) (<HOLDING>). This case, then, is governed by the rule that
holding that where a merger clause is included in the written contract alleged collateral promises will not be enforced through fraud because under fraud the reliance must be reasonable holding that consistent with parol evidence rule a merger clause can be avoided based on fraud in the inducement holding that justifiable reliance is a jury question where the contract containing the merger clause was found invalid due to an antecedent fraud holding that under federal law the party seeking to obviate the forum selection clause must prove that the inclusion of the clause was the result of fraud or coercion  fraud in the inducement as to the entire contract is not enough holding that the only fraud that could vitiate the contract is fraud that would invalidate the merger clause itself ie fraud relating to the merger clause or fraud that invalidates the entire contract including the merger clause quoting 3 corbin contracts  578