Iowa Code
Iowa Code § 554.2713 (2026)
Buyer’s damages for nondelivery or repudiation
✓ current as of July 2026
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1. Subject to the provisions of this Article with respect to proof of market price (section 554.2723), the measure of damages for nondelivery or repudiation by the seller is the difference between the market price at the time when the buyer learned of the breach and the contract price together with any incidental and consequential damages provided in this Article (section 554.2715), but less expenses saved in consequence of the seller’s breach.
2. Market price is to be determined as of the place for tender or, in cases of rejection after arrival or revocation of acceptance, as of the place of arrival. [C24, 27, 31, 35, 39, §9996; C46, 50, 54, 58, 62, §554.68; C66, 71, 73, 75, 77, 79, 81, §554.2713] Referred to in §554.2711, 554.2723 \n
Notes of Decisions
Cited in 6
cases (1 in the last 5 years), 1975–2026 · leading case: Cargill, Inc. v. Fickbohm, 252 N.W.2d 739 (Iowa 1977).
Cargill, Inc. v. Fickbohm, 252 N.W.2d 739 (Iowa 1977). “The Commercial Code draftsmen state in Comment 1 to § 554.2713,1.C.A.: “The general baseline adopted in this section uses as a yardstick the market in which the buyer would have obtained cover had he sought that relief.”
Carson v. Mulnix, 263 N.W.2d 701 (Iowa 1978). “The court based its damage calculations on section 554.2713 of the Code which is as follows: “1.”
Kanzmeier v. McCoppin, 398 N.W.2d 826 (Iowa 1987). “The measure of damages must be the difference between the contract price and the market price at the time the plaintiff learned of the breach, plus incidental and consequential damages, as prescribed by section 554.2713. We note that both parties spent much of their energy at…”
Hayes v. Hettinga, 228 N.W.2d 181 (Iowa 1975). “2711, which says: “Where the seller fails to make delivery or repudiates or the buyer rightfully rejects or justifiably revokes acceptance then * * * the buyer may cancel and * * * may in addition to recovering so much of the price as has been paid * * (b) recover damages for…”
H-W-H Cattle Co., Inc. v. Clayton Schroeder, 767 F.2d 437 (8th Cir. 1985). “Iowa Code Ann. § 554.2713 (West 1967). HWH contended before the district court, as it does here, that it is entitled to damages based upon the market price of cattle meeting the contract description in Artesia, New Mexico on June 1, 1979, the day after the last day of delivery…”
CMT High., LLC, an Iowa Ltd. Co. v. Logan Contractors Supply, Inc., an Iowa Corp. (Iowa 2026). “§ 554.2713(1). Or it can procure substitute goods, id.”
— Iowa Code § 554.2713(1) — 3 cases
Cargill, Inc. v. Fickbohm, 252 N.W.2d 739 (Iowa 1977). “The Commercial Code draftsmen state in Comment 1 to § 554.2713,1.C.A.: “The general baseline adopted in this section uses as a yardstick the market in which the buyer would have obtained cover had he sought that relief.”
Hayes v. Hettinga, 228 N.W.2d 181 (Iowa 1975). “2711, which says: “Where the seller fails to make delivery or repudiates or the buyer rightfully rejects or justifiably revokes acceptance then * * * the buyer may cancel and * * * may in addition to recovering so much of the price as has been paid * * (b) recover damages for…”
CMT High., LLC, an Iowa Ltd. Co. v. Logan Contractors Supply, Inc., an Iowa Corp. (Iowa 2026). “§ 554.2713(1). Or it can procure substitute goods, id.”
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