Minnesota Statutes

Minn. Stat. § 604.101 (2026)

Economic Loss Doctrine

✓ current as of May 2026

Find cases: SyfertCases citing this section MN-REVrevisor.mn.gov (official) Justiaon Justia CornellLII Search CasesGoogle Scholar

Subdivision 1.Definitions.

(a) The definitions in this subdivision apply to this section.

(b) "Buyer" means a person who buys or leases or contracts to buy or lease the goods that are alleged to be defective or the subject of a misrepresentation.

(c) "Goods" means tangible personal property, regardless of whether that property is incorporated into or becomes a component of some different property.

(d) "Period of restoration" means the time a reasonable person would find reasonably necessary to repair, replace, rebuild, or restore other tangible property and real property harmed by the defect in the goods to a quality level reasonably equivalent to the quality level that existed before the defect caused the harm, but excluding in all circumstances:

(1) time necessary to repair, replace, rebuild, or restore the goods themselves;

(2) delays or other impediments resulting from a difficulty in obtaining financing; and

(3) delays or other impediments resulting from zoning or environmental requirements imposed by law that did not apply to the use of the harmed property immediately before the harm occurred.

(e) "Product defect tort claim" means a common law tort claim for damages caused by a defect in the goods but does not include statutory claims. A defect in the goods includes a failure to adequately instruct or warn.

(f) "Seller" means a person who sells or leases or contracts to sell or lease the goods that are alleged to be defective or the subject of a misrepresentation.

(g) If a good is a component of a manufactured good, harm caused by the component good to the manufactured good is not harm to tangible personal property other than the component good.

Subd. 2.Scope.

This section does not apply to claims for injury to the person. This section applies to any claim by a buyer against a seller for harm caused by a defect in the goods sold or leased, or for a misrepresentation relating to the goods sold or leased:

(1) regardless of whether the seller and the buyer were in privity regarding the sale or lease of the goods; and

(2) regardless of whether article 2 or 2A of the Uniform Commercial Code under chapter 336 governed the sale or lease that caused the seller to be a seller and buyer to be a buyer.

Subd. 3.Limits on product defect tort claims.

A buyer may not bring a product defect tort claim against a seller for compensatory damages unless a defect in the goods sold or leased caused harm to the buyer's tangible personal property other than the goods or to the buyer's real property. In any claim brought under this subdivision, the buyer may recover only for:

(1) loss of, damage to, or diminution in value of the other tangible personal property or real property, including, where appropriate, reasonable costs of repair, replacement, rebuilding, and restoration;

(2) business interruption losses, excluding loss of good will and harm to business reputation, that actually occur during the period of restoration; and

(3) additional family, personal, or household expenses that are actually incurred during the period of restoration.

Subd. 4.Limits on common law misrepresentation claims.

A buyer may not bring a common law misrepresentation claim against a seller relating to the goods sold or leased unless the misrepresentation was made intentionally or recklessly.

Subd. 5.Relation to common law.

The economic loss doctrine applies to claims only as stated in this section. This section does not alter the elements of a product defect tort claim or a common law claim for misrepresentation.

Subd. 6.Application; effect on existing statute.

This section governs claims by a buyer against a seller if the sale or lease that caused the seller to be a seller and the sale or lease that caused the buyer to be a buyer both occurred on or after August 1, 2000. Section 604.10 does not apply to a claim governed by this section.

Notes of Decisions

Cited in 29 cases (8 in the last 5 years), 2000–2026 · leading case: Valspar Refinish, Inc. v. Gaylord's, Inc., 764 N.W.2d 359 (Minn. 2009).

Sort: Relevance Newest Treatment

Valspar Refinish, Inc. v. Gaylord's, Inc., 764 N.W.2d 359 (Minn. 2009). · cites it 19× “In Minn.Stat. § 604.101 (2008), the legislature limited a buyer’s ability to bring a common-law claim against a seller based on a misrepresentation that relates to goods that have been sold.”

Johnson v. Bobcat Co., 175 F. Supp. 3d 1130 (D. Minnesota 2016). · cites it 9× “See Minn. Stat. § 604.101 , subdiv. 2. Under the statute, “a buyer may not bring a product defect tort claim for compensatory damages unless the defect ‘caused harm to the buyer’s tangible personal property other than the goods or the buyer’s real property.”

Luckey v. Alside, Inc., 245 F. Supp. 3d 1080 (D. Minnesota 2017). · cites it 8× “Under Minn. Stat. § 604.101 , “a buyer may not bring a product defect tort claim for compensatory damages unless the defect ‘caused harm to the buyer’s tangible personal property other than the goods or the buyer’s real property.”

Ptacek v. Earthsoils, Inc., 844 N.W.2d 535 (Minn. Ct. App. 2014). · cites it 24× “In Minnesota, the economic-loss doctrine is codified in Minn.Stat. § 604.101. “The economic loss doctrine applies to claims only as stated in [section 604.”

Driscoll v. Stand. Hardware, Inc., 785 N.W.2d 805 (Minn. Ct. App. 2010). · cites it 9× “Minnesota’s economic-loss doctrine, codified at Minn.Stat. § 604.101, places limits on both product-defect tort claims and common-law misrepresentation claims arising from the sale or lease of goods.”

Daigle v. Ford Motor Co., 713 F. Supp. 2d 822 (D. Minnesota 2010). · cites it 5× “” Minn.Stat. § 604.101, subd. 3 (2010). There is no bar against claims for an injury to a person, however.”

George v. Uponor Corp., 988 F. Supp. 2d 1056 (D. Minnesota 2013). · cites it 9× “In this case, Defendants argue Plaintiffs have failed to allege any actual injury (a matter of standing) and also that Plaintiffs have failed to allege any recoverable damages resulting from their alleged injury (a matter relevant to the economic loss doctrine).”

Thunanber v. Uponor, Inc., 887 F. Supp. 2d 850 (D. Minnesota 2012). · cites it 3× “2d at 829-30 , this Court applied the economic loss doctrine, finding that the plaintiffs’ tort claims for negligence and strict liability were barred by Minn.Stat. § 604.101. The plaintiffs were minivan owners who brought a putative class action, alleging that a design defect…”

All Metro Glass, Inc. v. Tubelite, Inc., 227 F. Supp. 3d 1007 (D. Minnesota 2016). · cites it 4× “” Minn. Stat. § 604.101 , subd. 3. “ ‘Goods’ means tangible personal property, regardless of whether that property is incorporated into or becomes a component of some different property.”

Grams v. Milk Prods., Inc., 2005 WI 112 (Wis. 2005). · cites it 2× “91); Minn. Stat. § 604.101 (created by 2000 Minn.”

Giles v. Gen. Motors Acceptance Corp., 494 F.3d 865 (9th Cir. 2007). “”); see also Minn.Stat. § 604.101 (codifying Minnesota’s doctrine, which limits compensatory damages only in product liability cases and permits claims of intentional or reckless misrepresentation regarding the goods).”

Minnesota Pipe & Equip. Co. v. Ameron Int'l Corp., 938 F. Supp. 2d 862 (D. Minnesota 2013). · cites it 4× “Minn.Stat. § 604.101, subd. 4. However, MN Pipe did not purchase or lease any Ameron pipe from Ameron because Ameron pipe was ultimately deemed not suitable for the project.”

Show all 29 citing cases →

Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.