Federal Appeals Court Affirms Jury Verdict in Egg-Farm Barn Collapse

02.05.2026

In Rembrandt Enterprises, Inc. v Tecno Poultry Equipment, SpA,137 F.4^th 896 (8^th Cir. 2025), the United States Court of Appeals for the Eighth Circuit affirmed a jury verdict in favor of the designer and manufacturer of an egg farm’s poultry case system. Rembrandt Enterprises, Inc., owns and operates an egg farm in Rembrandt, Iowa. Tecno Poultry Equipment, SpA, is an Italian designer and manufacturer of poultry housing systems. Rembrandt hired Tecno to design and manufacture a poultry cage system for installation in four of Rembrandt’s egg-farm barns. “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.’” Rembrandt hired a third party to assemble and install the cage system, which was completed in 2007.

“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 on several theories, one of them being that “Tecno was negligent in supervising installation of the cage system.” That negligence claim went to trial, and the “jury found that Tecno did not breach a duty to supervise the installation and returned a verdict in favor of the defense.” Rembrandt appealed.

Rembrandt made two arguments on appeal: (1) “there was insufficient evidence to support the verdict because no reasonable jury could find that Tecno adequately supervised the installation of the cage system,” so “the district court should not have submitted the issue to the jury and should have granted judgment as a matter of law for Rembrandt,” and (2) the district court should not have excluded from the jury a “screenshot of Tecno's [2023] website [which] . . . describes services that Tecno offers when it installs a ‘turnkey’ cage system [and] states that Tecno's ‘experts will ensure each system is installed correctly and includes the right accessories,’” because it showed “Tecno's understanding of the term ‘supervision’” in its contract with Rembrandt.

The appeals court rejected both arguments. The court refused to consider the first argument because Rembrandt failed to preserve the issue for appeal. Although “Rembrandt [raised the argument when it] filed a motion for judgment as a matter of law under Rule 50(a) after Tecno presented its case-in-chief,” and although “Rembrandt renewed [the argument in] its motion at the close of the evidence before the case was submitted to the jury,” “Rembrandt did not renew [the argument in a] motion under Rule 50(b)” after the jury returned its verdict and judgment was entered. This failure forfeited the argument on appeal.

On the second argument, the court agreed with the district court that the screenshot was not relevant to the case. “The web page was dated nearly seventeen years after the parties formed the contract. The 2006 contract did not promise a ‘turnkey’ system and did not define ‘supervision’ in accordance with the 2023 web page. The web page is Tecno's advertisement about a particular cage system for potential clients at a later date. The web page from 2023 did not tend to show the intent of the parties in 2006 when they formed the contract at issue in this case.”