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Illinois Compiled Statutes

810 ILCS 5/2-714 (2026)

Buyer's damages for breach in regard to accepted goods

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(810 ILCS 5/2-714) (from Ch. 26, par. 2-714)
    Sec. 2-714. Buyer's damages for breach in regard to accepted goods.
    (1) Where the buyer has accepted goods and given notification (subsection (3) of Section 2-607 he may recover as damages for any non-conformity of tender the loss resulting in the ordinary course of events from the seller's breach as determined in any manner which is reasonable.
    (2) The measure of damages for breach of warranty is the difference at the time and place of acceptance between the value of the goods accepted and the value they would have had if they had been as warranted, unless special circumstances show proximate damages of a different amount.
    (3) In a proper case any incidental and consequential damages under the next section may also be recovered.
(Source: Laws 1961, p. 2101.)

    
Notes of Decisions
Cited in 14 cases (3 in the last 5 years), 1997–2023 · leading case: Razor v. Hyundai Motor Am., 854 N.E.2d 607 (Ill. 2006).
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Razor v. Hyundai Motor Am., 854 N.E.2d 607 (Ill. 2006). “" 810 ILCS 5/2-714(2) (West 2000). "While it is not necessary that damages for breach of warranty be calculated with mathematical precision [citation], basic contract theory requires that damages be proved with reasonable certainty and precludes damages based on conjecture or…”
Loeffel Steel Prods., Inc. v. Delta Brands, Inc., 387 F. Supp. 2d 794 (N.D. Ill. 2005). “’ ” The UCC provides that “[t]he measure of damages for breach of warranty is the difference at the time and place of acceptance between the value of the goods accepted and the value they would have had if they had been as warranted, unless special circumstances show proximate…”
Jones v. Fleetwood Motor Homes, 127 F. Supp. 2d 958 (N.D. Ill. 2000). “Moreover, it would not be an appropriate exercise of equity to order rescission. of an $88,000 purchase 8 based on delays depriving plaintiff of only $1,250 worth of use.”
Janis v. Workhorse Custom Chassis, LLC, 891 F. Supp. 2d 970 (N.D. Ill. 2012). “810 ILCS 5/2-714(2); see Razor v. Hyundai Motor Am.”
IMI Norgren Inc. v. D & D Tooling & Mfg., Inc., 247 F. Supp. 2d 966 (N.D. Ill. 2002). “” 810 ILCS 5/2-714(2); Continental Sand & Gravel, Inc.”
Van Hoekelen Greenhouses, Inc v. Work 6, Inc., 2023 IL App (1st) 220858-U (Ill. App. Ct. 2023). · cites it 5× “Credits for Poinsettia Plants ¶ 49 Next, Work 6 claims that the trial court erred in calculating its damages for VHG’s delivery of poinsettia plants and failed to comply with section 2-714 of the UCC (810 ILCS 5/2-714). In particular, Work 6 contends that the trial court “failed…”
Razor v. Hyundai Motor Am. (Ill. App. Ct. 2004). · cites it 2× “” 810 ILCS 5/2-714(2) (West 2000). The UCC also provides for incidental and consequential damages in proper cases.”
Shoop v. DaimlerChrysler Corp. (Ill. App. Ct. 2007). · cites it 2× “810 ILCS 5/2-714(2) (West 2004); Razor v.”
Nutraceuticals v. ZAC Packing, LLC (Ill. App. Ct. 2021). “Lifeline Ambulance, LLC, 2020 IL 124610 to argue that the issue of measure of damages involves an interpretation of a statute, presumably and Illinois Uniform Commercial Code (UCC) section 2-714, (810 ILCS 5/2-714(2) (West 2018)), and the burdens imposed by law.”
Albrosco Ltd. v. Prince Agri Prods. Inc. (C.D. Ill. 2021). “810 ILCS 5/2-714(3). Consequential damages include “injury to person or property proximately resulting from any breach of warranty.”
Tudor v. Jewel Food Stores, Inc. (Ill. App. Ct. 1997). · cites it 2× “In count II, plaintiff pleaded a violation of sections 2-714 and 2-715 of the Uniform Commercial Code (810 ILCS 5/2-714, 2-715 (West 1992)). In count III, plaintiff alleged a theory of unjust enrichment.”
Magnum Press Automation, Inc. v. Thomas & Betts Corp. (Ill. App. Ct. 2001). “See 810 ILCS 5/2-714 (West 2000). The cases cited by T&B similarly involve recovery under warranty theories and therefore are not directly on point because they involve slightly different issues.”
Show all 14 citing cases →
— 810 ILCS 5/2-714(1) — 1 case
Van Hoekelen Greenhouses, Inc v. Work 6, Inc., 2023 IL App (1st) 220858-U (Ill. App. Ct. 2023). “Credits for Poinsettia Plants ¶ 49 Next, Work 6 claims that the trial court erred in calculating its damages for VHG’s delivery of poinsettia plants and failed to comply with section 2-714 of the UCC (810 ILCS 5/2-714). In particular, Work 6 contends that the trial court “failed…”
— 810 ILCS 5/2-714(2) — 10 cases
Razor v. Hyundai Motor Am., 854 N.E.2d 607 (Ill. 2006). “" 810 ILCS 5/2-714(2) (West 2000). "While it is not necessary that damages for breach of warranty be calculated with mathematical precision [citation], basic contract theory requires that damages be proved with reasonable certainty and precludes damages based on conjecture or…”
Loeffel Steel Prods., Inc. v. Delta Brands, Inc., 387 F. Supp. 2d 794 (N.D. Ill. 2005). “’ ” The UCC provides that “[t]he measure of damages for breach of warranty is the difference at the time and place of acceptance between the value of the goods accepted and the value they would have had if they had been as warranted, unless special circumstances show proximate…”
Janis v. Workhorse Custom Chassis, LLC, 891 F. Supp. 2d 970 (N.D. Ill. 2012). “810 ILCS 5/2-714(2); see Razor v. Hyundai Motor Am.”
IMI Norgren Inc. v. D & D Tooling & Mfg., Inc., 247 F. Supp. 2d 966 (N.D. Ill. 2002). “” 810 ILCS 5/2-714(2); Continental Sand & Gravel, Inc.”
Shoop v. DaimlerChrysler Corp. (Ill. App. Ct. 2007). “810 ILCS 5/2-714(2) (West 2004); Razor v.”
— 810 ILCS 5/2-714(3) — 2 cases
Albrosco Ltd. v. Prince Agri Prods. Inc. (C.D. Ill. 2021). “810 ILCS 5/2-714(3). Consequential damages include “injury to person or property proximately resulting from any breach of warranty.”
Razor v. Hyundai Motor Am. (Ill. App. Ct. 2004). “” 810 ILCS 5/2-714(2) (West 2000). The UCC also provides for incidental and consequential damages in proper cases.”
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