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Huiskamp v. Moline Wagon Co

• 1886 • 121 U.S. 310 • Waite Court
In Huiskamp v. Moline Wagon Co, the United States Supreme Court was asked to decide whether a patentee could recover damages for infringement of a patent that had been declared invalid by a court of competent jurisdiction. The plaintiff, Huiskamp, had obtained a patent for a wagon wheel hub and had sued the defendant, Moline Wagon Co, for infringement. The district court found that the patent was invalid and dismissed the case. Huiskamp appealed to the Supreme Court, arguing that he should be...Open Case
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Chief Waite Court
Term: 1886
Docket: 194
121 U.S. 310
7 S. Ct. 899
30 L. Ed. 971
1887 U.S. LEXIS 2054
Argued: Apr 06, 1887

Huiskamp v. Moline Wagon Co

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Opinion Summary
AI Abstract

In Huiskamp v. Moline Wagon Co, the United States Supreme Court was asked to decide whether a patentee could recover damages for infringement of a patent that had been declared invalid by a court of competent jurisdiction. The plaintiff, Huiskamp, had obtained a patent for a wagon wheel hub and had sued the defendant, Moline Wagon Co, for infringement. The district court found that the patent was invalid and dismissed the case. Huiskamp appealed to the Supreme Court, arguing that he should be able to recover damages for infringement even if the patent was found to be invalid. The Supreme Court held that a patentee could not recover damages for infringement of a patent that had been declared invalid by a court of competent jurisdiction. The Court reasoned that a patentee should not be allowed to benefit from a patent that had been found to be invalid, as this would be contrary to public policy. The Court also noted that the patentee had the opportunity to appeal the decision of the lower court, but had failed to do so. The Court's decision in Huiskamp v. Moline Wagon Co established that a patentee cannot recover damages for infringement of a patent that has been declared invalid by a court of competent jurisdiction. This decision has been cited in numerous subsequent cases and remains good law today.

Dissent Summary
AI Abstract

Justice Field delivered the dissenting opinion in Huiskamp v. Moline Wagon Co, arguing that the majority's decision was wrongfully based on a misapplication of Illinois law. He argued that under Illinois law, an employer is liable for injuries caused by their employees' negligence if they are acting within the scope of their employment and have been entrusted with dangerous machinery or tools. The plaintiff had alleged that his injury was caused by a defective wagon wheel which he claimed to be due to negligent construction or repair work done by one of defendant's employees while working at its factory. Justice Field argued that since this employee was operating within the scope and course of his employment when he allegedly committed negligence, it should not matter whether he acted as an independent contractor or servant; therefore, liability should still attach to defendant company regardless of how it classified him for other purposes such as taxation or wages. Furthermore, Justice Field noted that even if there were any doubt about whether this employee fell into either category under Illinois law - which there wasn't - then it would be up to a jury trial rather than summary judgment from the court below in order to determine who bore responsibility for plaintiff’s injury

Opinion written by Justice SBlatchford
Decided: Apr 18, 1887
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