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James River Equipment Co. v. Beadle County Equipment Co.

646 N.W.2d 265 (2002)

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James River Equipment Co. v. Beadle County Equipment Co.

South Dakota Supreme Court
646 N.W.2d 265 (2002)

RW

Facts

James River Equipment Company (James River) (plaintiff) purchased farm equipment owned by Beadle County Equipment Company (Beadle County) (defendant). The sales contract expressly warranted the accuracy of all representations made by Beadle County. The contract also stated that James River bought the equipment as is and that Beadle County made no representations as to the equipment’s condition. Beadle County gave James River an opportunity to inspect the equipment prior to sale, but James River did not take advantage of that opportunity. After the sale, James River discovered that some of the equipment had usage issues that affected the equipment’s value. James River sued Beadle County for breaching Beadle County’s express warranty. The case was governed by South Dakota’s version of Uniform Commercial Code (UCC) § 2-316. The trial court ruled that James River’s failure to inspect the equipment, combined with the contract’s as-is clause, negated any express warranty otherwise conveyed by the contract. The trial court entered judgment for Beadle County. James River appealed to the South Dakota Supreme Court.

Rule of Law

Issue

Holding and Reasoning (Wilbur, J.)

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