Jason Cannon v. Bodensteiner Implement Company, Windridge Implements, LLC, Eck & Glass, Inc., d/b/a EPG Insurance, Inc., and CNH America LLC, d/b/a Case IH

Summary

The Iowa Court of Appeals reviews the grant of summary judgment in Jason Cannon’s claims arising from his purchase of a defective Case IH tractor. The court affirms summary judgment on most claims, including fraudulent misrepresentation, implied warranties, and breach of the implied covenant of good faith and fair dealing, but reverses on the express-warranty claim because a fact question existed regarding the seller’s representations that the tractor was in good condition and ready for use. The matter is remanded for further proceedings.

Holdings

1. Summary judgment was proper because Cannon failed to produce evidence that Bodensteiner knowingly made false representations, acted with scienter or intent to deceive, or concealed material information subject to a duty of disclosure.
2. The written sales agreement conspicuously and effectively disclaimed the implied warranties of merchantability and fitness for a particular purpose.
3. Summary judgment was improper on Cannon's express-warranty claim because a genuine issue of material fact existed regarding whether Monroe's statements that the tractor was in good condition, fit, field-ready, and ready to go constituted an express warranty.
4. Summary judgment was proper because Cannon identified no contractual term to which an implied duty of inspection or disclosure could attach, and the implied covenant cannot create new substantive contractual obligations.
5. Summary judgment was proper on equitable rescission because Cannon had adequate remedies at law and did not establish the requirements for extraordinary equitable relief.
6. The economic-loss doctrine barred Cannon's negligence claim because his alleged damages resulted solely from the tractor's failure to function properly and did not involve personal injury or damage to other property.
7. CNH was not liable under the purchased protection plan because CNH was not shown to be a party to that agreement, which identified EPG as the provider.
8. Summary judgment was proper because Cannon presented no evidence that CNH made a misleading statement, concealed material information, had contact with Cannon before the purchase, or intended Cannon to rely on any concealment or nondisclosure.
9. Summary judgment was proper because EPG could not breach the purchased protection plan by failing to pay expenses that were never submitted to it; the amounts submitted were either paid or written off.

Questions Presented

1. Whether Cannon presented a genuine issue of material fact on his fraudulent misrepresentation or fraudulent nondisclosure claims against Bodensteiner.
2. Whether the written sales agreement effectively disclaimed implied warranties.
3. Whether statements that the tractor was in good condition, fit, field-ready, and ready to go could constitute an express warranty despite the written disclaimer.
4. Whether Cannon's claim for breach of the implied covenant of good faith and fair dealing against Bodensteiner could proceed without an express contractual term requiring inspection or disclosure.
5. Whether equitable rescission was available when Cannon had adequate remedies at law.
6. Whether the economic-loss doctrine barred Cannon's negligence claim against CNH for losses arising from the defective tractor.
7. Whether CNH was liable under the purchased protection plan or for fraudulent concealment or nondisclosure.
8. Whether EPG breached the purchased protection plan by failing to pay amounts that were not submitted for reimbursement.

Disposition

reversed_and_remanded