Narrative Opinion Summary
The case involves Grand Island Express's appeal against a summary judgment granted in favor of Timpte Industries, Inc., based on statute of limitations grounds. In 1984, Grand Island purchased fifty-two refrigerated trailers from Timpte, which came with a five-year warranty. By 1986, defects in the trailers' flooring were apparent, leading to extensive repairs and consultations that revealed design flaws. Grand Island filed suit on August 21, 1991, alleging breach of warranty and misrepresentation. The court applied Nebraska law, specifically Neb.Rev.Stat. U.C.C. Sec. 2-725, which mandates a four-year limitations period for breach of contract actions starting from the breach's discovery. The court found that Grand Island had discovered the breach prior to August 21, 1987, rendering the claims time-barred. The court also dismissed Grand Island's misrepresentation claims, as they were similarly constrained by the four-year statute of limitations. The district court's summary judgment was affirmed, as no genuine issues of material fact were found, precluding Grand Island's late claims. Judge John F. Nangle affirmed the judgment, underscoring the procedural application of the statute of limitations under Nebraska law.
Legal Issues Addressed
Accrual of Cause of Action for Breach of Warrantysubscribe to see similar legal issues
Application: The court determined that the cause of action accrued when the breach was discovered, not at delivery, due to the warranty extending to future performance. The discovery of the breach prior to August 21, 1987, rendered the claim time-barred.
Reasoning: A cause of action accrues upon breach, regardless of the buyer's knowledge, with a breach of warranty occurring at delivery unless a warranty extends to future performance, in which case the cause accrues upon discovery of the breach (Neb.Rev.Stat. U.C.C. Sec. 2-725(2)).
Discovery Rule in Warranty Casessubscribe to see similar legal issues
Application: The court applied the discovery rule, acknowledging that the warranty's future performance clause allowed for tolling of the statute of limitations until the defect was discovered, which occurred before August 21, 1987.
Reasoning: In this case, Timpte's warranty for the trailers explicitly covered five years, allowing for the discovery exception to apply, which tolled the statute of limitations until Grand Island discovered the breach.
Misrepresentation and Statute of Limitationssubscribe to see similar legal issues
Application: The court dismissed Grand Island's misrepresentation claims, determining they were also subject to the four-year statute of limitations, commencing upon discovery of the alleged fraud.
Reasoning: Furthermore, even if Grand Island's claims of intentional misrepresentation were adequately pleaded, they were also subject to the four-year statute of limitations starting from the discovery of the fraud.
Statute of Limitations under Neb.Rev.Stat. U.C.C. Sec. 2-725subscribe to see similar legal issues
Application: The case applies Nebraska's statute of limitations for breach of contract, which requires such actions to be initiated within four years of the cause of action accruing. The court found the plaintiff's suit time-barred since the breach was discovered before August 21, 1987.
Reasoning: Under Nebraska law, a buyer must initiate a breach of contract action against a seller within four years of the cause of action accruing, as stated in Neb.Rev.Stat. U.C.C. Sec. 2-725(1).
Summary Judgment and Genuine Issues of Material Factsubscribe to see similar legal issues
Application: The court affirmed summary judgment for Timpte, finding no genuine issues of material fact existed that would preclude judgment as a matter of law, given the evidence of Grand Island's awareness of the defects by 1987.
Reasoning: The appellate court reviewed the summary judgment de novo, focusing on whether any genuine issues of material fact existed and if Timpte was entitled to judgment as a matter of law.