The First Circuit Court of Appeals recently affirmed a district court’s denial of John Deere’s post-trial motions for a new trial or for judgment as a matter of law in its favor. Casco, Inc. v. John Deere Const. & Forestry Co., 900 F.3d 1 (1st Cir. 2021). Casco was a reseller of Deere construction equipment in Puerto Rico pursuant to an agreement Casco entered into with Deere in 1986. In 2012, Deere canceled a purchase order from Casco for an excavator that Casco had sold to a construction company. In 2013, Deere terminated the agreement with Casco citing past-due payments and various other defaults. Casco filed suit in federal court in Puerto Rico alleging unjust impairment under Puerto Rico’s Dealer Protection Act based on Deere’s cancellation of the 2012 purchase order, and also alleging unjust termination of the agreement. The jury found for Casco on both claims. Deere filed a motion for judgment as a matter of law on the termination claim and a motion for a new trial on both claims. The district court denied both motions.
In its opinion, the First Circuit affirmed both rulings. Regarding the unjust impairment claim, the court found that, even though Casco’s employees had not completed all the required training to be authorized to sell excavators, the jury had been presented with enough evidence showing Deere had not adequately provided access to said training. Because the jury properly weighed the competing evidence, it was reasonable that they could have come to such a conclusion. Concerning the unjust termination, the jury was presented with evidence of previous instances where Deere had overlooked late payments and the fact that timely payment was not expressly listed in the “Essential Obligation” section of the agreement, as well as evidence that Deere was not happy Casco had developed a relationship with a Deere competitor. The First Circuit concluded that based on such facts, the jury reasonably found that termination of the agreement based on late payments was unjust.