Robert M. Speight and Beverly E. Speight v. Walters Development Company, Ltd.

Summary

The Iowa Supreme Court held that a subsequent purchaser of a home may bring a claim against the builder-vendor for breach of the implied warranty of workmanlike construction. The court also held that the discovery rule applied to the claim, so the action was not barred by Iowa's five-year statute of limitations, and remanded the case for further proceedings.

Holdings

1. Under Iowa law, a subsequent purchaser may recover against a builder-vendor for breach of the implied warranty of workmanlike construction, even without contractual privity with the builder-vendor.
2. The Speights' implied-warranty action was not barred by the five-year statute of limitations because the discovery rule applies and they filed suit within five years of acquiring knowledge of the alleged defect.
3. Iowa Code section 614.1(11)'s fifteen-year statute of repose applies to implied-warranty claims based on an unsafe or defective condition of an improvement to real property, and the period begins upon completion of the construction.

Questions Presented

1. Whether subsequent purchasers of a home may recover from the builder-vendor for breach of the implied warranty of workmanlike construction despite lacking contractual privity with the builder.
2. Whether the Speights' implied-warranty claim was barred by Iowa Code section 614.1(4)'s five-year statute of limitations.
3. Whether Iowa Code section 554.2725(2), which measures accrual of warranty claims from delivery, governed the claim.

Disposition

reversed_and_remanded