Schmitz-Werke GmbH Co. v. Rockland Industries, Inc.

A Rockland Industries (Rockland) (defendant) salesperson told Schmitz Werke (Schmitz) (plaintiff), a German fabric company, that its Trevira Blackout drapery fabric was a particularly good base for transfer printing, but repeated print tests by Schmitz's transfer printer, PMD, kept showing problems across multiple orders, ultimately leading Schmitz to try returning thousands of meters of the fabric. After negotiations failed, Schmitz sued under the CISG for breach of the warranty of fitness for a particular purpose, and the district court found Rockland had warranted the fabric's suitability for transfer printing and that Schmitz's evidence -- without needing expert testimony pinpointing the defect's exact nature -- showed both the printing problems and Schmitz's reasonable reliance on Rockland's representations; Rockland appealed.