Jason Cannon v. Bodensteiner Implement Company, 903 N.W.2d 322

Background

Cannon, an independent contractor who hauls liquid manure, bought a used 2008 Case IH Magnum 305 from Bodensteiner Implement (a John Deere dealer) without inspecting or test-driving it.
Salesperson Monroe made oral statements that the tractor was "in good condition," "field ready," and suitable for manure hauling; Monroe also said the seller would include a transferable Purchase Protection Plan (PPP).
After delivery Cannon immediately experienced serious mechanical problems (broken turbo bolts, gear failure, hydraulic pump failure, recurring transmission overheating and brake failures); PPP covered some repairs but problems persisted and Cannon called the tractor a "lemon."
Cannon sued Bodensteiner (among others) alleging fraudulent misrepresentation, breach of implied and express warranties, and related claims; district court granted summary judgment for defendants, finding the written purchase agreement disclaimed express warranties other than the PPP.
The court of appeals affirmed most of the district court but found a genuine issue whether Monroe’s oral assurances created an express warranty; Iowa Supreme Court granted further review limited to the express-warranty/disclaimer issue.
The Supreme Court assumed (for argument) an oral express warranty existed but held the written purchase agreement’s clear disclaimers effectively negated any express dealer warranty, affirming summary judgment for Bodensteiner.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Monroe’s oral statements created an express warranty	Cannon: Monroe’s assurances that the tractor was "fit," "field ready," and "in good condition" constituted express warranties relied on by Cannon	Bodensteiner: Any oral warranties were disclaimed by the written purchase agreement and parol evidence cannot override the integration/disclaimer	Court assumed arguendo an express warranty could exist but resolved the case on the disclaimer: the written disclaimers negate any such oral express warranty
Whether the written purchase agreement is fully integrated and bars oral modification	Cannon: Oral statements should be admissible to create a contractual term	Bodensteiner: The written contract (signed by both) is the final expression; parol evidence cannot contradict clear disclaimers	Court: Agreement treated as fully integrated for purposes of disclaimer; parol evidence cannot be used to negate clear written disclaimers absent preserved challenges
Adequacy/conspicuousness of disclaimer language	Cannon: Disclaimers were small-print and arguably limited to John Deere products, so not effective	Bodensteiner: Disclaimers were explicit, signed, and clearly stated no dealer warranty on used products	Court: Disclaimers were sufficiently clear and effective; Cannon failed to preserve argument that disclaimers were post-agreement or insufficiently conspicuous
Preservation of procedural objections to disclaimer/parol evidence	Cannon: Contended disclaimer was ineffective because it was provided after an oral agreement	Bodensteiner: Cannon did not preserve that argument below; parol evidence rule bars the claim	Court: Cannon failed to preserve the timing/conspicuousness challenge in district court; appellate review limited and argument forfeited

Key Cases Cited

C & J Vantage Leasing Co. v. Wolfe, 795 N.W.2d 65 (Iowa 2011) (integration and parol-evidence principles; fully integrated agreement is a factual question)
Bartlett Grain Co., LP v. Sheeder, 829 N.W.2d 18 (Iowa 2013) (parol evidence cannot be used to reverse clear written terms)
Limited Flying Club, Inc. v. Wood, 632 F.2d 51 (8th Cir. 1980) (distinguishing situations where an "as is" clause may not be a complete and exclusive statement)
Williams v. Mid-Iowa Equip., Inc., 223 F. Supp. 3d 866 (S.D. Iowa 2015) (similar facts: "field ready" statement and an "as is"/no-warranty invoice; parol evidence limitations)
Midwest Printing, Inc. v. Am Int'l, Inc., 108 F.3d 168 (8th Cir. 1997) (contract disclaimer effective to bar express-warranty claims)