Sorchaga v. Ride Auto, LLC, 909 N.W.2d 550

Sorchaga bought a salvage-title pickup from Ride Auto after a short test drive; the sales documents repeatedly stated the truck was sold "AS IS — NO WARRANTY."
During the sale Ride Auto's salesman told Sorchaga the check‑engine light was due to a faulty oxygen sensor that would be easy to fix, and that the ASC third‑party warranty (promised by Ride Auto) would cover repairs.
Ride Auto knew the truck had serious engine damage when it purchased the vehicle from a salvage yard and did not correct the salesperson's statements.
After purchase the truck performed poorly, emitted excessive smoke, and a dealer later advised the engine needed full replacement (~$20,000); Sorchaga paid for an inspection and could not obtain promised warranty coverage.
Sorchaga sued for breach of implied warranty of merchantability, Magnuson‑Moss Act violations, and fraud; the trial court found fraud and awarded damages and attorney fees.
The court of appeals affirmed; the Minnesota Supreme Court reviewed whether seller fraud defeats an "as is" disclaimer under Minn. Stat. § 336.2‑316 and whether awarding relief on both fraud and warranty claims was erroneous.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether seller fraud about a good's condition prevents enforcement of an "as is" disclaimer under Minn. Stat. § 336.2‑316	Fraud is a "circumstance" surrounding the transaction that "indicates otherwise," making the disclaimer ineffective	"Unless the circumstances indicate otherwise" is limited to facts showing parties didn't intend to exclude warranties; oral statements cannot override a written "as is" disclaimer	Court held fraudulent misrepresentations about fitness are a "circumstance" that render "as is" disclaimers ineffective under § 336.2‑316(3)(a)
Whether plaintiff may recover on both fraud and breach of warranty theories (risk of double recovery)	UCC permits remedies for fraud and does not bar warranty damages after rescission; rescission doesn't renounce warranty claims	Fraud vitiates the contract and thus voids warranties, so plaintiff should not recover twice	Court held UCC allows separate remedies; plaintiff may recover on both theories so long as there is no double recovery — the award here did not permit double recovery

Murray v. D & J Motor Co., 958 P.2d 823 (Okla. Ct. App. 1998) (fraudulent representations about condition can render an "as is" disclaimer unreasonable)
Valspar Refinish, Inc. v. Gaylord's, Inc., 764 N.W.2d 359 (Minn. 2009) (elements and standards for fraud)
Blankenship v. Northtown Ford, Inc., 420 N.E.2d 167 (Ill. App. 1981) (technical disclaimer compliance insufficient where dealer misrepresented condition)
Specialized Tours, Inc. v. Hagen, 392 N.W.2d 520 (Minn. 1986) (permitting separate claims for fraud and breach of contract so long as no double recovery)
State v. Randolph, 800 N.W.2d 150 (Minn. 2011) (guide to reading UCC provisions in context of related provisions)
McDonald v. Johnson & Johnson, 776 F.2d 767 (8th Cir. 1985) (fraud in inducement and subsequent breach can be distinct causes of action under Minnesota law)