Williams v. Mid-Iowa Equipment, Inc.
223 F. Supp. 3d 866
| S.D. Iowa | 2015Background
- Kevin Williams bought a 1997 John Deere 8300 tractor at an online auction from Mid‑Iowa for $49,900 in December 2012; invoice stated sale was "AS IS" and no warranties.
- Williams did not inspect the tractor before wiring payment and later spent $16,495.98 on repairs and new tires.
- Williams alleges breach of contract (tractor not as represented: hours, horsepower, oil leak, and not "100% field ready") and fraud; rescission was abandoned, so only damages remain.
- Mid‑Iowa moved for summary judgment, arguing the "AS IS" terms exclude warranty-based contract claims and there is no evidence of intent to deceive for fraud.
- Court treated requests for admission against Williams (deeming he purchased under Mid‑Iowa’s terms and did not allege intent to deceive) and viewed disputed facts in Williams’s favor for summary‑judgment purposes.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the seller’s statement "100% field ready" or listing details became contractual terms overcoming the "AS IS" sale | Williams: statement by owner Vos and listing representations created terms or ambiguity allowing parol evidence to show breach | Mid‑Iowa: listing and invoice explicitly made sale "AS IS" with no guarantees; no mutual assent to add "100% field ready" term | Held for Mid‑Iowa—no mutual assent; "AS IS" sale controls and parol evidence does not create new contract term |
| Whether implied duties of good faith convert listing descriptions into contract terms | Williams: UCC and general duty of good faith prevent seller from disavowing diligence and truthful descriptions | Mid‑Iowa: duty of good faith governs performance, not formation; cannot create substantive terms absent agreement | Held for Mid‑Iowa—good faith does not add substantive contract terms; summary judgment for contract claim |
| Whether Williams presented clear, satisfactory, and convincing evidence of fraud (including intent to deceive) | Williams: inaccurate listing information and that Mid‑Iowa could have verified hours/horsepower and known oil leak supports inference of intent | Mid‑Iowa: inaccuracies alone are insufficient; plaintiff admitted he did not allege intent to deceive via requests for admission | Held for Mid‑Iowa—deemed admission that no intent alleged is fatal; no non‑speculative evidence of scienter |
| Whether federal diversity jurisdiction exists given claimed damages | Williams: pleaded punitive damages plus repair costs bring controversy over $75,000 threshold | Mid‑Iowa: punitive claim unlikely to meet jurisdictional amount; argues amount in controversy is legally insufficient | Held for court: diversity jurisdiction exists—punitive damages could plausibly raise amount to threshold under applicable due‑process ratio analysis |
Key Cases Cited
- Schubert v. Auto Owners Ins. Co., 649 F.3d 817 (8th Cir.) (plaintiff's claimed amount controls unless legal certainty shows jurisdictional amount not met)
- Ondrisek v. Hoffman, 698 F.3d 1020 (8th Cir.) (due‑process considerations for punitive damages ratios)
- State Farm Mut. Auto. Ins. Co. v. Campbell, 538 U.S. 408 (U.S. Supreme Court) (constitutional limits on punitive damages and ratio guidance)
- Rucker v. Taylor, 828 N.W.2d 595 (Iowa) (mutual assent and formation principles for contract terms)
- Cornell v. Wunschel, 408 N.W.2d 369 (Iowa) (elements and heightened evidentiary standard for fraud claim)
- Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574 (U.S. Supreme Court) (summary judgment standards)
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (U.S. Supreme Court) (standard for genuine issue of material fact for summary judgment)