From Casetext: Smarter Legal Research

Electrical Corp. v. Thomas Co.

U.S.
May 22, 1939
307 U.S. 241 (1939)

Summary

holding that a party can seek reformation of a favorable decree that discusses issues immaterial to the final outcome

Summary of this case from Pension Trust Fund v. Federal Ins. Co.

Opinion

CERTIORARI TO THE CIRCUIT COURT OF APPEALS FOR THE SECOND CIRCUIT.

No. 582.

Argued April 19, 1939. Decided May 22, 1939.

A defendant in a patent suit is entitled to appeal from so much of a decree adjudging him not guilty of infringement as purports to adjudge the patent valid. P. 242. 100 F.2d 403, reversed.

CERTIORARI, 306 U.S. 624, to review the dismissal of an appeal from a decree of the District Court, 23 F. Supp. 920, in a suit for alleged patent infringement.

Mr. Samuel E. Darby, Jr., with whom Mr. Lloyd H. Crews was on the brief, for petitioners.

Mr. George Whitefield Betts, Jr., with whom Messrs. William Bohleber and Francis H. Fassett were on the brief, for respondents.


This was a suit in equity by the respondents for alleged infringement of a patent. The District Court held claim 1 valid but not infringed and claim 2 invalid. Instead of dismissing the bill without more, it entered a decree adjudging claim 1 valid but dismissing the bill for failure to prove infringement.

The respondents did not appeal, but filed in the Patent Office a disclaimer of claim 2. The petitioners appealed to the Circuit Court of Appeals from so much of the decree as adjudicated claim 1 valid. The appeal was dismissed on the ground that the petitioners had been awarded all the relief to which they were entitled, the litigation having finally terminated in their favor. The court was of opinion that the decree would not bind the petitioners in subsequent suits on the issue of the validity of claim 1.

We granted certiorari because of an alleged conflict of decision. A party may not appeal from a judgment or decree in his favor, for the purpose of obtaining a review of findings he deems erroneous which are not necessary to support the decree. But here the decree itself purports to adjudge the validity of claim 1, and though the adjudication was immaterial to the disposition of the cause, it stands as an adjudication of one of the issues litigated. We think the petitioners were entitled to have this portion of the decree eliminated, and that the Circuit Court of Appeals had jurisdiction, as we have held this court has, to entertain the appeal, not for the purpose of passing on the merits, but to direct the reformation of the decree.

See Oliver-Sherwood Co. v. Patterson-Ballagh Corp., 95 F.2d 70, 71.

Lindheimer v. Illinois Bell Tel. Co., 292 U.S. 151, 176.

See 28 U.S.C. § 225.

Gully v. Interstate Natural Gas Co., 292 U.S. 16; Oklahoma Gas Electric Co. v. Oklahoma Packing Co., 292 U.S. 386; William Jameson Co. v. Morgenthau, ante, p. 171.

The judgment is reversed, and the cause is remanded to the Circuit Court of Appeals with instructions to entertain the appeal and direct the District Court to reform its decree in accordance with the views herein expressed.

Reversed.


Summaries of

Electrical Corp. v. Thomas Co.

U.S.
May 22, 1939
307 U.S. 241 (1939)

holding that a party can seek reformation of a favorable decree that discusses issues immaterial to the final outcome

Summary of this case from Pension Trust Fund v. Federal Ins. Co.

vacating finding of patent validity because District Court had dismissed complaint on noninfringement grounds

Summary of this case from Reuber v. U.S.

In Electrical Fittings, the District Court held one claim of a patent valid but not infringed. The patentee was content with that judgment, but the successful defendant appealed, seeking a reversal of the finding of validity.

Summary of this case from Cardinal Chem. Co. v. Morton Int'l, Inc.

In Electrical Fittings the decree of the District Court adjudged the patent valid but dismissed the complaint for failure to prove infringement.

Summary of this case from Deposit Guaranty Nat. Bank v. Roper

In Electrical Fittings, a limited appeal was allowed because the petitioner himself was prejudiced by the inclusion of an unnecessary and adverse finding in a generally favorable decree.

Summary of this case from Deposit Guaranty Nat. Bank v. Roper

In Electrical Fittings, the petitioners asserted a concern that their success in some unspecified future litigation would be impaired by stare decisis or collateral-estoppel application of the District Court's ruling on patent validity.

Summary of this case from Deposit Guaranty Nat. Bank v. Roper

In Electrical Fittings, the district court found that (1) the plaintiff's patent was valid and (2) the defendants did not infringe the patent.

Summary of this case from Yunker v. Allianceone Receivables Mgmt., Inc.

In Electrical Fittings Corp. v. Thomas Betts Co., 307 U.S. 241, 241-42, 59 S.Ct. 860, 83 L.Ed. 1263 (1939), a district court found that a patent was valid but that the plaintiff had failed to prove infringement.

Summary of this case from In re Wingerter

prevailing party in patent dispute entitled to appeal collateral ruling on the validity of a patent claim

Summary of this case from Leonard v. Nationwide Mutual Insurance

prevailing party in patent dispute entitled to appeal collateral ruling on the validity of a patent claim

Summary of this case from Leonard v. Nationwide Mut

prevailing party had standing to appeal where district court found no infringement, but improperly adjudged the patent valid

Summary of this case from National Presto Industries v. Dazey Corp.

In Electrical Fittings Corp. v. Thomas Betts Co., 307 U.S. 241, 59 S.Ct. 860, 83 L.Ed. 1263 (1939), the District Court had entered a judgment for the defendant, finding that the defendant had not infringed the plaintiff's patent but also finding that the patent was valid.

Summary of this case from Ashley v. Boehringer Ingelheim Pharmaceuticals

In Electrical Fittings, the district court, on a bill and answer, held the patent in suit "valid" but not infringed. The patentee did not appeal. However, the victorious defendant sought to appeal the judgment to the extent it ruled the patent "valid."

Summary of this case from Morton Intern., v. Cardinal Chemical Co.

In Electrical Fittings Corp. v. Thomas Betts Co., 307 U.S. 241, 59 S.Ct. 860, 83 L.Ed. 1263 (1939), respondents had sued petitioners for patent infringement.

Summary of this case from Alltrade, Inc. v. Uniweld Prods., Inc.

prevailing party entitled to appeal when it had already received all the relief it was entitled to but feared that a ruling on an immaterial issue might later be the basis for collateral estoppel

Summary of this case from Delaware Valley Citizens Council v. Davis

allowing successful defendants in patent infringement suit to appeal from declaration that the patent, though not infringed, was valid

Summary of this case from Showtime Networks Inc. v. F.C.C

In Electrical Fittings Corp. v. Thomas Betts Co., 307 U.S. 241, 59 S.Ct. 860, 83 L.Ed. 1263 (1939), the interest identified was the prospect that an unfavorable ruling would act as collateral estoppel in subsequent litigation.

Summary of this case from Int'l Broth. of Elec. Workers v. I.C.C

In Electrical Fittings, the petitioners asserted a concern that their success in some unspecified future litigation would be impaired by stare decisis or collateral estoppel application of the District Court's ruling on patent validity.

Summary of this case from Vieau v. Japax, Inc.

allowing victorious defendants in patent infringement suit to appeal to eliminate from the decree the finding that the patent, though not infringed, was valid — a finding with direct and significant impact on the appellant

Summary of this case from Balcom v. Lynn Ladder and Scaffolding Co.

In Electrical Fittings Corp. v. Thomas Betts Co., 307 U.S. 241, 59 S.Ct. 860, 83 L.Ed. 1263, the Supreme Court held that a defendant in a suit for patent infringement who appealed from a decree adjudicating a claim of the patent sued upon valid although not infringed was entitled to reformation of the decree by eliminating therefrom the portion dealing with validity so that it would not stand as an adjudication of that issue, and this in spite of the fact that the decree as it originally stood finally terminated the litigation in the defendant's favor.

Summary of this case from Addressograph-Multigraph Corp. v. Cooper

In Electrical Fittings Corp. v. Thomas Betts Co., 307 U.S. 241, 59 S.Ct. 860, 83 L. Ed. 1263, a case was presented where the district court had decreed a patent claim valid but not infringed. Instead of dismissing the bill without more, the district court, Thomas Betts Co. v. Electrical Fittings Corp., 23 F. Supp. 920, had entered a decree adjudging the claim valid, but dismissing the bill because infringement had not been proved.

Summary of this case from Hazeltine Corporation v. Crosley Corporation

establishing parties may not appeal judgments in their favor

Summary of this case from Walker v. Walden
Case details for

Electrical Corp. v. Thomas Co.

Case Details

Full title:ELECTRICAL FITTINGS CORP. ET AL. v . THOMAS BETTS CO. ET AL

Court:U.S.

Date published: May 22, 1939

Citations

307 U.S. 241 (1939)
59 S. Ct. 860

Citing Cases

Wabash Corp. v. Ross Electric Corp.

Thus there was an investigation and determination as to validity to comply with the above mentioned better…

United States v. Fletcher

Moreover, because appellate courts review judgments, not opinions, see Ward, 393 F.3d at 603, “[a] party may…