Despite a general rule in Louisiana that a court may not consider parol evidence to alter the terms of a previously agreed-upon written contract, the Fifth Circuit Court of Appeals held in King v. University Healthcare System, L.C., 645 F. 3d 713 (5th Cir. 2011), that a Louisiana district court acted within its discretion in granting an anesthesiologist latitude to submit parol evidence in an attempt to prove her breach of contract claim against University Healthcare System (UHS). The anesthesiologist filed suit alleging that her former employer violated the Equal Pay Act and Louisiana’s Wage Payment law, as well as other statutes. Specifically, she argued that her employment contract had been modified by a subsequent oral agreement to pay her for extra hours worked due to a shortage of anesthesiologists after Hurricane Katrina. Although the Fifth Circuit held that the trial court properly admitted evidence in support of an oral contract, the court ultimately reversed the jury’s verdict that the employer breached an oral agreement for the extra pay. The Fifth Circuit further held that the jury’s award to the anesthesiologist under the Louisiana Wage Payment law was plain error because the statute’s often-contested language requiring employers to pay the compensation “due under the terms of employment” must be premised on some identifiable obligation. Since the jury concluded that there was no agreement between the parties regarding extra payment, the jury’s award under the wage payment statute was erroneous.