Iowa Code

Iowa Code § 554.2715 (2026)

Buyer’s incidental and consequential damages

✓ current as of July 2026
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1. Incidental damages resulting from the seller’s breach include expenses reasonably incurred in inspection, receipt, transportation and care and custody of goods rightfully rejected, any commercially reasonable charges, expenses or commissions in connection with effecting cover and any other reasonable expense incident to the delay or other breach.

2. Consequential damages resulting from the seller’s breach include

a. any loss resulting from general or particular requirements and needs of which the seller at the time of contracting had reason to know and which could not reasonably be prevented by cover or otherwise; and

b. injury to person or property proximately resulting from any breach of warranty. [C24, 27, 31, 35, 39, §9998, 9999; C46, 50, 54, 58, 62, §554.70, 554.71; C66, 71, 73, 75, 77, 79, 81, §554.2715] Referred to in §554.2712, 554.2713, 554.2714 \n

Notes of Decisions
Cited in 22 cases (1 in the last 5 years), 1970–2026 · leading case: Des Moines Flying Serv., Inc. v. Aerial Servs. Inc. Cedar Valley Aviation, LLC & Kirk P. Fisher, 880 N.W.2d 212 (Iowa 2016).
Des Moines Flying Serv., Inc. v. Aerial Servs. Inc. Cedar Valley Aviation, LLC & Kirk P. Fisher, 880 N.W.2d 212 (Iowa 2016). · cites it 6× “” Iowa Code § 554.2715 (2)(b). Section 1 of the Restatement (Third) of Torts: Products Liability, adopted by our court in Wright v.”
Nationwide Agribusiness Ins. v. SMA Elevator Constr. Inc., 816 F. Supp. 2d 631 (N.D. Iowa 2011). · cites it 6× “On the other hand, “consequential economic loss” is defined in Iowa Code § 554.2715 (2) as (a) any loss resulting from general or particular requirements and needs of which the seller at the time of contracting had reason to know and which could not reasonably be prevented by…”
Beyond the Garden Gate, Inc. v. Northstar Freeze-Dry Mfg., Inc., 526 N.W.2d 305 (Iowa 1995). · cites it 4× “Incidental and consequential damages are covered in Iowa Code section 554.2715: (1) Incidental damages resulting from the seller’s breach include expenses reasonably incurred in inspection, receipt, transportation and care and custody of goods rightfully rejected, any…”
Shinrone, Inc. v. Tasco, Inc., 283 N.W.2d 280 (Iowa 1979). · cites it 3× “The buyer may recover from the seller as damages the difference between the *285 cost of cover and the contract price together with any incidental or consequential damages as hereinafter defined (section 554.2715), but less expenses saved in consequence of the seller’s breach.”
Renze Hybrids, Inc. v. Shell Oil Co., 418 N.W.2d 634 (Iowa 1988). · cites it 2× “1982); Iowa Code § 554.2715 (consequential damages for seller’s breach).”
Carson v. Mulnix, 263 N.W.2d 701 (Iowa 1978). · cites it 2× “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…”
Trs. of Iowa Laborers Dist. Council Health & Welfare Trust v. Ankeny Cmty. Sch. Dist., 865 N.W.2d 270 (Iowa Ct. App. 2014). · cites it 4× “A buyer may recover consequential damages from a breaching seller pursuant to Iowa Code section 554.2715. 8 Recoverable consequential economic losses “inelude[] loss of profits resulting from failure of the goods to function as warranted, loss of goodwill, .”
W & W Livestock Enter., Inc. v. Dennler, 179 N.W.2d 484 (Iowa 1970). · cites it 2× “70 (7) : ‘In the case of breach of warranty of quality, such loss, in the absence of special circumstances showing proximate damage of a greater amount, is the difference between the value of the goods at the time of delivery to the buyer and the value they would have had if…”
Winter v. Honeggers'& Co., Inc., 215 N.W.2d 316 (Iowa 1974). · cites it 2× “” Section 554.2715(2)b — “Consequential damages resulting from the seller’s breach include * * * b.”
Metro. Transfer Station, Inc. v. Design Structures, Inc., 328 N.W.2d 532 (Iowa Ct. App. 1982). · cites it 2× “By analogy, interest may be recoverable as a “consequential” damage under Iowa Code § 554.2715 (1981) within the meaning of the Uniform Commercial Code.”
Cargill, Inc. v. Fickbohm, 252 N.W.2d 739 (Iowa 1977). · cites it 3× “2713(1), a buyer’s usual measure of damages for nondelivery 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…”
Kanzmeier v. McCoppin, 398 N.W.2d 826 (Iowa 1987). · cites it 2× “Iowa Code § 554.2715 (2)(a). See also Cargill, Inc.”
— Iowa Code § 554.2715(1) — 1 case
Des Moines Flying Serv., Inc. v. Aerial Servs. Inc. Cedar Valley Aviation, LLC & Kirk P. Fisher, 880 N.W.2d 212 (Iowa 2016). “” Iowa Code § 554.2715 (2)(b). Section 1 of the Restatement (Third) of Torts: Products Liability, adopted by our court in Wright v.”
— Iowa Code § 554.2715(2) — 4 cases
Des Moines Flying Serv., Inc. v. Aerial Servs. Inc. Cedar Valley Aviation, LLC & Kirk P. Fisher, 880 N.W.2d 212 (Iowa 2016). “” Iowa Code § 554.2715 (2)(b). Section 1 of the Restatement (Third) of Torts: Products Liability, adopted by our court in Wright v.”
Beyond the Garden Gate, Inc. v. Northstar Freeze-Dry Mfg., Inc., 526 N.W.2d 305 (Iowa 1995). “Incidental and consequential damages are covered in Iowa Code section 554.2715: (1) Incidental damages resulting from the seller’s breach include expenses reasonably incurred in inspection, receipt, transportation and care and custody of goods rightfully rejected, any…”
Winter v. Honeggers'& Co., Inc., 215 N.W.2d 316 (Iowa 1974). “” Section 554.2715(2)b — “Consequential damages resulting from the seller’s breach include * * * b.”
Shinrone, Inc. v. Tasco, Inc., 283 N.W.2d 280 (Iowa 1979). “The buyer may recover from the seller as damages the difference between the *285 cost of cover and the contract price together with any incidental or consequential damages as hereinafter defined (section 554.2715), but less expenses saved in consequence of the seller’s breach.”
— Iowa Code § 554.2715(2)(a) — 1 case
Cargill, Inc. v. Fickbohm, 252 N.W.2d 739 (Iowa 1977). “2713(1), a buyer’s usual measure of damages for nondelivery 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…”
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