Global Quest, LLC v. Horizon Yachts, Inc., 849 F.3d 1022

Background

Global Quest bought a 105-foot yacht (“Starlight”) from Horizon Yachts, Inc. (Seller), manufactured in Taiwan by Horizon Yacht Co., Ltd. and Premier Yacht Co., Ltd.; Seller acted as Horizon’s U.S. agent.
Purchase Agreement contained an "as is" warranty disclaimer but an Addendum inserted a negotiated limited written warranty (Exhibit A) and provided the Addendum governs inconsistent terms.
Limited warranty (on Seller letterhead, referencing “Horizon Group” and listing Premier) covered certain manufacturing/design defects for one year and disclaimed other warranties unless altered by an executive officer.
After delivery, Global Quest discovered serious defects (noncompliance with MCA LY2 and DNV standards, range and electrical problems); defendants allegedly refused repairs under the warranty.
Global Quest sued for multiple counts (including fraudulent inducement; breach of implied warranties; breach of express limited warranty); Seller counterclaimed to foreclose a promissory note. District court granted summary judgment to defendants on most claims and to Seller on its counterclaim; court certified partial final judgment under Rule 54(b).
Eleventh Circuit vacated summary judgment as to Counts I (fraudulent inducement), III/IV/VII (breach of implied warranties), and VIII (breach of express limited warranty against Seller) and reversed summary judgment on Seller’s counterclaim; affirmed the remainder and remanded for trial.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether fraud-in-the-inducement claim is barred by "as is"/integration clauses	Oceanic Villas controls: an "as is" or integration clause does not bar fraud unless contract expressly disclaims fraud; thus fraud claim may proceed	Contract integration and "as is" clauses preclude reliance on pre-contractual representations; plaintiff's reliance unreasonable	Reversed district court: fraud claim not barred as a matter of law; genuine factual disputes exist and claim may proceed to trial
Whether economic loss rule bars fraud claim	Fraud is distinct from contract breach; economic loss rule limited to products-liability context per Tiara	Economic-loss doctrine precludes tort recovery for purely economic harms	Court held Tiara limits economic-loss rule to product liability; fraud claim not barred here
Whether Magnuson-Moss bars disclaimer of implied warranties when a limited written warranty is given	Section 2308(a) prohibits disclaiming implied warranties when any written (full or limited) warranty is provided	Limited warranties are not governed by MMWA; UCC/state law governs disclaimers	Reversed: MMWA §2308(a) applies to limited warranties; disclaimer may be ineffective if a jury finds a written limited warranty was provided
Whether Seller (Horizon Yachts, Inc.) issued or is bound by the limited express warranty (privity/incorporation)	Warranty was negotiated with Seller, provided on Seller letterhead, listed in Closing Index, Addendum references Exhibit A — jury could find Seller issued or bound by it; agency/privity with manufacturer possible	Warranty language and documents distinguish “Horizon Group” from Seller; paragraph language suggests Seller did not issue or agree to be bound	Reversed: genuine issues of material fact exist as to incorporation/privity; jury must decide whether Seller (or manufacturers) issued/are bound by the warranty

Key Cases Cited

Oceanic Villas, Inc. v. Godson, 4 So. 2d 689 (Fla. 1941) (an "as is" clause does not bar fraud claims absent an express contractual waiver of fraud)
Tiara Condominium Ass'n, Inc. v. Marsh & McLennan Cos., 110 So. 3d 399 (Fla. 2013) (economic-loss rule applies only in products-liability context)
Butler v. Yusem, 44 So. 3d 102 (Fla. 2010) (elements of fraud in the inducement under Florida law)
Puryear v. State, 810 So. 2d 901 (Fla. 2002) (Florida Supreme Court precedent remains controlling until expressly overruled)
Celotex Corp. v. Catrett, 477 U.S. 317 (Sup. Ct. 1986) (summary judgment standard)