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Wheeler v. IDN-Armstrong's, Inc.
Citations: 288 Ga. App. 253; 653 S.E.2d 835; 2007 Fulton County D. Rep. 3483; 2007 Ga. App. LEXIS 1185Docket: A07A1863
Court: Court of Appeals of Georgia; November 6, 2007; Georgia; State Appellate Court
Following a bench trial, the State Court of Cobb County ruled in favor of IDN-Armstrong’s, Inc. in its lawsuit against Randall Wheeler and Charles Poff regarding an open account. Wheeler appealed the judgment, arguing that the trial court improperly valued witness testimony that contradicted the terms of an unambiguous written instrument. IDN had supplied goods to A-Metro Lock & Safe, with Wheeler and Poff as owners, based on an open account application they executed. IDN presented invoices indicating goods delivered to A-Metro, each marked “paid.” However, IDN's account manager testified that none of the invoices had been paid, explaining that the “paid” status was automatically generated by the bookkeeping system upon reprinting invoices after an account was removed from accounts payable. Wheeler contested the amount owed, claiming he made cash payments for each delivery, but the trial court found his evidence unpersuasive and ruled in favor of IDN. Wheeler's appeal claimed that the account manager's explanation constituted inadmissible parol evidence, contradicting the invoices as unambiguous written instruments. However, the court determined that Wheeler did not demonstrate that the invoices qualified as “valid written instruments” under OCGA 24-6-1, which typically refers to legal documents defining rights or obligations. The court emphasized that invoices are merely detailed statements of goods and do not establish contractual rights or duties. The court concluded that the parol evidence rule's limited scope allows for explanations regarding invoices, and since the invoices were not deemed written instruments, the trial court did not err in considering testimony about the “paid” notation. Consequently, the judgment was affirmed.