Iowa Code

Iowa Code § 554.2714 (2026)

Buyer’s damages for breach in regard to accepted goods

✓ current as of July 2026

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1. Where the buyer has accepted goods and given notification (section 554.2607, subsection 3) the buyer may recover as damages for any nonconformity 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 section 554.2715 may also be recovered. [C24, 27, 31, 35, 39, §9998; C46, 50, 54, 58, 62, §554.70; C66, 71, 73, 75, 77, 79, 81, §554.2714] 2008 Acts, ch 1032, §78; 2015 Acts, ch 29, §99 \n

Notes of Decisions

Cited in 6 cases, 1980–2020 · leading case: Flom v. Stahly, 569 N.W.2d 135 (Iowa 1997).

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Flom v. Stahly, 569 N.W.2d 135 (Iowa 1997). “Iowa Code § 554.2714 (1) (damages for nonconformity of goods may be “determined in any manner which is reasonable”); R.”

Midwest Hatchery & Poultry Farms, Inc. v. Doorenbos Poultry, Inc., 783 N.W.2d 56 (Iowa Ct. App. 2010). “See Iowa Code § 554.2714 . After considering Doorenbos Poultry’s counterclaim, the court found Midwest had breached the contract by providing pullets that were not of the specified age.”

Middletown Concrete Prods., Inc. v. Black Clawson Co., 802 F. Supp. 1135 (D. Del. 1992). “Iowa Code § 554.2714 (1). 18 . At oral argument, plaintiff noted its argument on this point was probably more akin to a motion in limine.”

William C. Mitchell, Ltd. v. Brown, 576 N.W.2d 342 (Iowa 1998). “In a proper case any incidental and consequential damages .”

Ltd. Flying Club, Inc. v. Wood, 632 F.2d 51 (8th Cir. 1980). “Iowa Code § 554.2714 (2), (3). It remains for the trier of fact to determine the amount of damages under this rule.”

Kevin H. Scott v. Jayco, Inc. (E.D. Cal. 2020). “20 The remedies provided by the commercial codes in Iowa ( Iowa Code Ann. § 554.2714 ) and by 21 California’s Commercial Code (§§ 2714, 2715) are the same.”

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