Bayside Holdings, Ltd. v. Viracon, Inc.
2013 U.S. App. LEXIS 4973
8th Cir.2013Background
- Bayside Holdings, Ltd., Bayside House, Ltd., and Bayside Pictet, Ltd. are Bahamian corporations.
- Viracon, a Minnesota manufacturer, and EFCO, a Missouri company, supplied the windows.
- Bayside installed Viracon-EFCO windows in a Bahamian commercial development; cracking and delamination followed.
- Nine years later Bayside sued for breach of warranty and related claims in federal court.
- The district court applied Minnesota’s two-year statute of limitations for express written warranties and granted summary judgment to EFCO and Viracon.
- The court affirmed dismissal of Bayside’s warranty claims, analyzing assignee and direct claims separately.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Bayside as Nassau Glass’s assignee is time-barred | Bayside as assignee should stand in Nassau Glass’s shoes | EFCO/Viracon contend claims accrued earlier and are time-barred | Time-barred for assignee warranty claims |
| Whether Bayside’s own warranty claims were timely | Discovery of breach occurred within the limitations period | Breach discovery occurred earlier; claims barred | Time-barred under discovery rule |
| Whether the discovery rule applies to express written warranties | Warranties extend; discovery should toll period | No tolling beyond when breach was discoverable | Discovery rule applied; claims untimely regardless |
Key Cases Cited
- Peterson v. Bendix Home Sys., Inc., 318 N.W.2d 50 (Minn. 1982) (elements of a warranty claim; causal link required)
- Vlahos v. R&I Constr. of Bloomington, Inc., 676 N.W.2d 672 (Minn. 2004) (two-year breach discovery rule for warranties)
- Ill. Farmers Ins. Co. v. Glass Serv. Co., 683 N.W.2d 792 (Minn. 2004) (assignment places assignee in assignor’s shoes)
- Doe v. Dept. of Veteran Affairs, 519 F.3d 456 (8th Cir. 2008) (nonmoving party must present substantial evidence; avoid speculation)
- DLH, Inc. v. Russ, 566 N.W.2d 60 (Minn. 1997) (genuine issue of material fact requires substantial evidence)
- Quinn v. St. Louis Cnty., 653 F.3d 745 (8th Cir. 2011) (summary judgment standard; de novo review)