Minnesota Statutes

Minn. Stat. § 604.10 (2026)

Economic Loss Arising From The Sale Of Goods

✓ current as of May 2026

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(a) Economic loss that arises from a sale of goods that is due to damage to tangible property other than the goods sold may be recovered in tort as well as in contract, but economic loss that arises from a sale of goods between parties who are each merchants in goods of the kind is not recoverable in tort.

(b) Economic loss that arises from a sale of goods, between merchants, that is not due to damage to tangible property other than the goods sold may not be recovered in tort.

(c) The economic loss recoverable in tort under this section does not include economic loss due to damage to the goods themselves.

(d) The economic loss recoverable in tort under this section does not include economic loss incurred by a manufacturer of goods arising from damage to the manufactured goods and caused by a component of the goods.

(e) This section shall not be interpreted to bar tort causes of action based upon fraud or fraudulent or intentional misrepresentation or limit remedies for those actions.

Notes of Decisions

Cited in 31 cases (3 in the last 5 years), 1992–2022 · leading case: Minnesota Forest Prods., Inc. v. Ligna Mach., Inc., 17 F. Supp. 2d 892 (D. Minnesota 1998).

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Minnesota Forest Prods., Inc. v. Ligna Mach., Inc., 17 F. Supp. 2d 892 (D. Minnesota 1998). · cites it 59× “If a claim arises out of the sale of goods, the doctrine is based upon Minn.Stat. § 604.10, but if it involves “a different type of Article 2 contract,” then the common law controls.”

Marvin Lumber & Cedar Co. v. PPG Indus., Inc., 34 F. Supp. 2d 738 (D. Minnesota 1999). · cites it 56× “Minn.Stat. § 604.10 (1998 Amend. § 4). However, this language does not indicate that the applicability of the Amendment was intended to be greater than the applicability of the previous statute.”

Grams v. Milk Prods., Inc., 2005 WI 112 (Wis. 2005). · cites it 6× “Further, the nature of a claim, tort or contract, may affect whether a particular person or entity is eligible as a defendant and whether a particular claim is covered by insurance.”

Nelson Distrib., Inc. v. Stewart-Warner Indus. Balancers, 808 F. Supp. 684 (D. Minnesota 1992). · cites it 14× “Plaintiff argues that Hapka’s ruling does not apply to bar claims of fraudulent misrepresentation and that, even if Hapka does bar such a claim, Minn.Stat. § 604.10 revives plaintiff’s claim and overrules Hapka .”

Jennie-O Foods, Inc. v. Safe-Glo Prods. Corp., 582 N.W.2d 576 (Minn. Ct. App. 1998). · cites it 15× “Appellant moved unsuccessfully for summary judgment on the ground that respondent was precluded from recovering in tort by the economic loss doctrine set out in Minn.Stat. § 604.10(a). A jury then determined that appellant was liable for fire damage to respondent’s property.”

Valspar Refinish, Inc. v. Gaylord's, Inc., 764 N.W.2d 359 (Minn. 2009). · cites it 2× “In addition, Minn.Stat. § 604.10 (2008), which addresses the recovery in tort for the economic loss from the sale of goods between parties who are merchants in goods of the kind, “does not apply to a claim governed by this section.”

State Farm Mut. Auto. Ins. Co. v. Ford Motor Co., 572 N.W.2d 321 (Minn. Ct. App. 1997). · cites it 10× “” See Minn.Stat. § 604.10 (1996) (adopting economic loss doctrine); see also Lloyd F.”

Bd. of Regents of the Univ. of Minnesota v. Chief Indus., Inc., 907 F. Supp. 1298 (D. Minnesota 1995). · cites it 11× “Minn.Stat. § 604.10 (1994). The placement of Minn.”

Marvin Lumber & Cedar Co. v. PPG Indus., Inc., 223 F.3d 873 (8th Cir. 2000). · cites it 6× “See Minn. Stat. § 604.10 . There is no statutory indication that the 1991 enactment was intended to apply retroactively.”

Marvin Lumber & Cedar Co. v. Sapa Extrusions, Inc., 964 F. Supp. 2d 993 (D. Minnesota 2013). · cites it 4× “” See Minn.Stat. § 604.10; Werwinski v. Ford Motor Co.”

Reinsurance Ass'n of Minnesota v. Timmer, 641 N.W.2d 302 (Minn. Ct. App. 2002). · cites it 2× “See Minn.Stat. § 604.10 (2000) (providing that economic loss arising from the sale of goods between merchants is not recoverable in tort, except in fraud actions).”

Holden Farms, Inc. v. Hog Slat, Inc., 347 F.3d 1055 (8th Cir. 2003). · cites it 4× “All the transactions in this matter occurred prior to August 1, 2000, and accordingly Minn.Stat. § 604.10 is the applicable statute in this case.”

Show all 31 citing cases →

— Minn. Stat. § 604.10(a) — 6 cases

Jennie-O Foods, Inc. v. Safe-Glo Prods. Corp., 582 N.W.2d 576 (Minn. Ct. App. 1998). “Appellant moved unsuccessfully for summary judgment on the ground that respondent was precluded from recovering in tort by the economic loss doctrine set out in Minn.Stat. § 604.10(a). A jury then determined that appellant was liable for fire damage to respondent’s property.”

Minnesota Forest Prods., Inc. v. Ligna Mach., Inc., 17 F. Supp. 2d 892 (D. Minnesota 1998). “If a claim arises out of the sale of goods, the doctrine is based upon Minn.Stat. § 604.10, but if it involves “a different type of Article 2 contract,” then the common law controls.”

Holden Farms, Inc. v. Hog Slat, Inc., 347 F.3d 1055 (8th Cir. 2003). “All the transactions in this matter occurred prior to August 1, 2000, and accordingly Minn.Stat. § 604.10 is the applicable statute in this case.”

State Farm Mut. Auto. Ins. Co. v. Ford Motor Co., 572 N.W.2d 321 (Minn. Ct. App. 1997). “” See Minn.Stat. § 604.10 (1996) (adopting economic loss doctrine); see also Lloyd F.”

Bd. of Regents of the Univ. of Minnesota v. Chief Indus., Inc., 907 F. Supp. 1298 (D. Minnesota 1995). “Minn.Stat. § 604.10 (1994). The placement of Minn.”

— Minn. Stat. § 604.10(b) — 1 case

In re Syngenta AG MIR 162 Corn Litig., 131 F. Supp. 3d 1177 (D. Kan. 2015).

— Minn. Stat. § 604.10(c) — 1 case

State Farm Mut. Auto. Ins. Co. v. Ford Motor Co., 572 N.W.2d 321 (Minn. Ct. App. 1997). “” See Minn.Stat. § 604.10 (1996) (adopting economic loss doctrine); see also Lloyd F.”

— Minn. Stat. § 604.10(d) — 2 cases

Marvin Lumber & Cedar Co. v. PPG Indus., Inc., 34 F. Supp. 2d 738 (D. Minnesota 1999). “Minn.Stat. § 604.10 (1998 Amend. § 4). However, this language does not indicate that the applicability of the Amendment was intended to be greater than the applicability of the previous statute.”

— Minn. Stat. § 604.10(e) — 5 cases

George v. Uponor Corp., 988 F. Supp. 2d 1056 (D. Minnesota 2013).

Cannon Tech., Inc. v. Sensus Metering Sys., Inc., 734 F. Supp. 2d 753 (D. Minnesota 2010).

State Farm Mut. Auto. Ins. Co. v. Ford Motor Co., 572 N.W.2d 321 (Minn. Ct. App. 1997). “” See Minn.Stat. § 604.10 (1996) (adopting economic loss doctrine); see also Lloyd F.”

Marvin Lumber & Cedar Co. Marvin Windows of Tennessee, Inc. v. Ppg Indus., Inc., Third Party v. Elf Atochem North Am., Inc., Third Party Minnesota, Amicus on Behalf Of, 223 F.3d 873 (3rd Cir. 2000).

Nw. Pub. Serv. v. Union Carbide Corp., 115 F. Supp. 2d 1164 (D.S.D. 2000).

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