Brown v. Louisiana-Pacific Corp., No. 15-1830 (8th Cir. 2016)
Annotate this CasePlaintiff filed suit against LP, alleging claims for fraudulent misrepresentation, unfair or deceptive practices, and breach of warranty against LP for the purported defectiveness of its TrimBoard product. The district court granted summary judgment to LP. In order for plaintiff to prevail on his fraudulent-misrepresentation claim under Iowa law, he must prove eight elements. At issue is the sixth element - justifiable reliance. In this case, plaintiff's builder's affidavit is insufficient to create a genuine issue of material fact as to whether the builder - a third party - received a communication from LP that he subsequently communicated to plaintiff and upon which plaintiff relied. Therefore, the district court did not err in rejecting defendant's fraudulent-misrepresentation claim. Likewise, plaintiff's unfair or deceptive practices claims fail. The court also concluded that the district court did not err in enforcing the terms of LP's limited warranty where the mere fact that the limited warranty does not compensate plaintiff for the entirety of his damages does not mean it has failed of its essential purpose, and where the limited warranty is neither procedurally nor substantively unconscionable. Accordingly, the court affirmed the district court's judgment.
Court Description: Smith, Author, with Riley, Chief Judge, and Shepherd, Circuit Judges] Civil case - Breach of warranty. In order to prevail on a fraudulent-misrepresentation claim under Iowa law, plaintiff had to prove that his contractor, upon whom he relied in selecting defendant's TrimBoard siding product, had actually reviewed materials from defendant or received a communication from defendant that he passed onto plaintiff and upon which plaintiff relied; he failed to do so, and the district court did not err in rejecting his fraudulent-misrepresentation claim; plaintiff's unfair or deceptive practices claims fails for the same reason; the district court did not err in enforcing the terms of defendant's limited warranty; the limited warranty is neither procedurally nor substantively unconscionable and is enforceable under Iowa law.
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