Beyond the Garden Gate, Inc. v. Northstar Freeze-Dry Manufacturing, Inc.

LAVORATO, Justice.

A third-party plaintiff purchased a used freeze dry machine from a seller who had purchased the machine from a third-party defendant-manufacturer. The district court submitted to the jury the third-party plaintiffs claim for breach of express warranty under Iowa’s Uniform Commercial Code (U.C.C.). As part of the claim, the court permitted the jury to consider direct economic loss damages and consequential economic loss damages. The jury refused to award the third-party plaintiff direct economic loss damages but did award consequential economic loss damages. Because we…