Lewis Refrigeration Co. v. Sawyer Fruit, Vegetable and Cold Storage Co.

Lewis Refrigeration (plaintiff) sold Sawyer (defendant) a commercial freezer under a contract warranting its performance and Freon requirements, with a warranty clause giving Lewis the right to promptly repair or replace any malfunctioning part, making rescission the only other remedy, and separately excluding consequential damages. After the freezer malfunctioned, Lewis significantly delayed repairs and testing, and Sawyer, unable to feasibly exercise rescission by the time it became clear the machine wouldn't work, eventually stopped paying the remaining contract balance. Lewis sued for that balance; Sawyer counterclaimed for breach and consequential damages. A jury awarded Lewis the balance due, but also awarded Sawyer $25,823 in lost profits and $27,080 in excess Freon costs. Lewis appealed several rulings, including the jury's consideration of whether the repair-and-rescission remedy failed its essential purpose and the court's failure to determine whether the consequential-damages limitation was unconscionable.