John Deere hit with 1.7 million verdict under Puerto Rico’s Dealers Act 75

In Casco, Inc. v. John Deere Constr. Co., Civil No.  13-1325 (PAD) (D.P.R. Mar. 30, 2017), Plaintiff Casco Inc. sued Defendant John Deere Construction & Forestry Company under the Puerto Rico Dealers Act, P.R. Laws Ann. tit. 10 §§ 278, et seq. (“Law 75”) and related statutes.

Law 75  protects Puerto Rico distributors (“dealers”) from a principal’s arbitrary termination or impairment of their commercial relationship; whom prior thereto developed a market for the principal’s products.

John Deere answered the complaint denying liability and counterclaimed against Casco for collection of unpaid invoices due. During trial, the court granted John Deere’s request to enter judgment on its $216,912.92 counterclaim. However, the jury awarded Casco $1,763,934.00 under Law 75. The parties filed motions to alter or amend judgment, for judgment as a matter of law, for remittitur and new trial.

The Federal Rules of Civil Procedure allows a party during a jury trial to move for judgment as a matter of law if the opposing party has been fully heard on an issue and there is no legally sufficient evidentiary basis for a reasonable jury to find for that party on that issue. Fed. R. Civ. P. 50(a). If the court does not grant the motion, then no later than 28 days after the entry of judgment, the movant may file a renewed motion for judgment as a matter of law and may include an alternative or joint request for a new trial. Fed. R. Civ. P. 50(b).

Courts can order a new trial if the verdict is clearly against the weight of the evidence and upholding it would result in an injustice. For that same reason, a court can also reduce the amount of the verdict (‘remittitur’). In such cases, the plaintiff can elect to remit a stated portion of the amount awarded as damages or submit to a new trial.  For a court to amend its judgment, the proponent must show through a motion that there is newly discovered material evidence or an intervening change in the law, or because the court committed a manifest error of law or fact. Fed. R. Civ. P.  59(e).

The court denied Defendant’s post-trial motions noting that there was a legally sufficient evidentiary basis for a reasonable jury to find defendant liable under Law 75. Upholding it will not result in a miscarriage of justice. Termination damages are properly supported. The jury confronted conflicting explanations from expert witnesses and chose one side over the other.