Rembrandt Enterprises, Inc. v. Tecno Poultry Equipment, SpA, formerly known as Tecno Poultry Equipment SRL

Cedar Rapids, Iowa civil litigation lawyers represented the parties in a product liability case.



Rembrandt owns and operates an egg farm in Rembrandt, Iowa, that produces,

processes, and distributes egg-based food products. Tecno, headquartered in Italy,

designs and manufactures poultry housing systems, such as egg collection equipment

and trolley feeding systems.



In 2006, the parties contracted for Tecno to design and manufacture a poultry

cage system to be installed in four barns at Rembrandt's egg farm. Tecno agreed to

furnish an on-site technician for ten weeks and to provide "supervision of

installation” of the cage system. The contract did not define "supervision.”



Tecno selected Andrzej Golebiewski to be the on-site technician during the

assembly and installation of the cage system. Because the contract did not provide

for Tecno to perform assembly or installation, Rembrandt contracted with a third

party to assemble and install the cage system.



The installation was completed in 2007. The cage system consisted of eight

rows of cages running the length of the barn. There were ten levels of cages divided

into two tiers. A catwalk ran between levels five and six, separating the two tiers.

Feed troughs and water tubes were placed on each row. An egg collection conveyer

and manure conveyer were placed on each tier.



On February 14, 2020, over a decade after the installation, the cage system in

one of the barns collapsed and killed one farm worker. The collapse caused

significant damage to the barn and destroyed eggs and hens.

Rembrandt sued Tecno in 2021 for strict products liability, breach of implied

warranties, and negligence. The district court concluded that there were genuine

issues of fact for trial on whether Tecno was negligent in supervising installation of

the cage system. The court granted summary judgment for Tecno on the remaining

claims.



The parties presented competing evidence about Tecno's duty to supervise the

installation. The jury also heard competing expert testimony about the cause of the

collapse. Rembrandt's expert stated that there were thousands of screws missing

from the cage system, and that several bolts used to connect the cage to the barn's

exterior were placed incorrectly. The expert opined that after weather and

temperature took their toll, the cage system ultimately collapsed because of the

missing screws and misplaced bolts. By contrast, Tecno's two experts testified that

Rembrandt did not properly dispose of the manure in the barn. They opined that as

manure built up, more weight was placed on the cage system, and the stress of the

weight caused the system to collapse.



After Tecno presented its evidence, Rembrandt moved for judgment as a matter

of law under Federal Rule of Civil Procedure 50(a). The motion argued that no

reasonable jury could find that Tecno adequately supervised the installation of the

cage system. The district court denied the motion. Rembrandt renewed its motion

at the close of the evidence before the case was submitted to the jury, and the court

again denied the motion. The jury found that Tecno did not breach a duty to

supervise the installation and returned a verdict in favor of the defense. The court

entered judgment for Tecno, and Rembrandt did not renew its motion for judgment

as a matter of law.



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Affirmed