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Christianson v. Colt Industries Operating Corp.

486 U.S. 800 (1988)

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Christianson v. Colt Industries Operating Corp.

United States Supreme Court

486 U.S. 800 (1988)

Facts

Colt Industries Operating Corp. (Colt) (defendant) was a manufacturer and seller of M16 rifles and accessories. Colt held patents and trade secrets related to M16s. Charles Christianson (plaintiff) was a former Colt employee who formed International Trade Services, Inc. (plaintiff) to sell M16 parts manufactured using information that Colt argued was protected. Christianson filed a lawsuit against Colt in federal district court alleging antitrust and tortious interference with business relationship claims related to Colt’s patents. The district court ruled in favor of Christianson and enjoined Colt from enforcing its purported trade secrets. Colt appealed to the United States Court of Appeals for the Federal Circuit. Colt chose this venue in the belief that the district court had jurisdiction over Christianson’s claims under 28 U.S.C. § 1338, which gave federal district courts jurisdiction over claims arising under federal laws related to patents. Additionally, 28 U.S.C. § 1295(a)(1) gave the Federal Circuit exclusive jurisdiction over appeals from a federal district court if the district court’s jurisdiction over the claim was based on § 1338. The Federal Circuit held that the district court’s jurisdiction was not based on § 1338, and therefore, the Federal Circuit did not have jurisdiction over the appeal. The Federal Circuit then transferred the case to the United States Court of Appeals for the Seventh Circuit. The Seventh Circuit held that the Federal Circuit’s decision regarding the jurisdictional question was wrong and transferred the case back to the Federal Circuit. The Federal Circuit responded by claiming that the Seventh Circuit’s decision on the jurisdictional question was wrong but heard the case and reversed the district court. The United States Supreme Court granted certiorari to resolve the jurisdictional question.

Rule of Law

Issue

Holding and Reasoning (Brennan, J.)

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