Rembrandt Enterprises, Inc. v. Tecno Poultry Equipment, SpA
137 F.4th 896
8th Cir.2025Background
- Rembrandt Enterprises contracted with Tecno Poultry Equipment, SpA in 2006 to design and supply a poultry cage system for its Iowa egg farm, with Tecno required to supervise installation but not perform it.
- Assembly and installation were done by a third party, with Tecno providing an on-site technician for supervision.
- In 2020, one of the cage systems collapsed, causing major property damage and a fatality.
- Rembrandt sued Tecno for strict liability, breach of implied warranties, and negligence; only the negligence claim (failure to supervise installation) went to trial.
- The jury found for Tecno, deciding no breach of a legal duty occurred; Rembrandt appealed, claiming trial errors.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence on supervision | Jury could not reasonably find proper supervision | Proper evidence supported their conduct | Not reviewable on appeal |
| Admissibility of 2023 Tecno web screenshot | Current advertising relevant to "supervision" | Too remote in time, not concerning 2006 | Properly excluded, irrelevant |
| Causation/fault (negligence elements) | Cage failed due to missing screws/installation | Collapse due to manure mismanagement | Not reached (no duty breach) |
| Preservation of legal challenges under Rule 50 | Motion for judgment as matter of law raised | Motion never renewed post-verdict | Issue forfeited on appeal |
Key Cases Cited
- Unitherm Food Sys., Inc. v. Swift-Eckrich, Inc., 546 U.S. 394 (procedural requirements under Rule 50; failure to file motion under 50(b) forfeits sufficiency challenge)
- Ortiz v. Jordan, 562 U.S. 180 (appellate courts cannot review sufficiency of evidence if post-verdict motion not made)
- Jackson v. Allstate Ins. Co., 785 F.3d 1193 (timely post-verdict motions are essential under Rule 50)