The plaintiff, R.J. Meyers Company, appealed a district court’s grant of summary judgment in favor of defendants, Reinke Manufacturing Company, Inc., and Hook’s Point Irrigation in a breach of warranty action.
In August of 2011, R.J. Meyers Company purchased an irrigation system from Hook’s Point irrigation. The irrigation system was manufactured by Reinke Manufacturing Co. The purchase agreement was exclusively between R.J. Meyers and Hook’s Point, however, the purchase agreement included Reinke’s certificate of warranty. The warranty limited actions for implied warranties. Reinke limited the remedy for breach of the express warranty to repair and replace the goods sold. After the system was installed in September 2011, R.J Meyers claims there were numerous, system-wide problems. R.J. Meyers filed action against Hook’s Point and Reinke, alleging numerous causes of action including breach of implied warranty of fitness for a particular purpose and breach of implied warranty of merchantability. Defendants filed motions for summary judgment. The district court granted summary judgment and found the disclaimers of the implied warranties were conspicuous, the plaintiff had an opportunity to read them, and the disclaimers were effective and endorsable.
On appeal, the court considered whether the disclaimer of implied warranties was enforceable. The Court held the UCC allows for the disclaimer of the implied warranties of merchantability and fitness so long as the disclaimers are in writing and conspicuous. See Iowa Code § 554.2316(2). The Court agreed with the district court: Reinke’s disclaimer was in writing, conspicuous, and the plaintiff had an opportunity to read it. Additionally, the Court found the warranty was not substantively or procedurally unconscionable, and therefore enforceable.