Graham v. John Deere Co.
United States Supreme Court
383 U.S. 1, 148 U.S.P.Q. (BNA) 459 (1966)
- Written by Craig Conway, LLM
Facts
William Graham (plaintiff) invented a device that used spring clamps to allow a chisel plow to flex up over obstructions in soil, such as large rocks, and then spring back down once the plow had passed the obstruction. This device prevented damage to the plow. Graham obtained patent number 2,493,811, referred to as the ’811 patent, for his device. Three years later, Graham received another patent, called the ’798 patent, for improvements to the ’811 patent’s design. Graham’s ’798 patent faced multiple challenges. Initially, the Fifth Circuit court of appeals upheld the patent. Later, Graham sued the John Deere Company (defendant), alleging it had infringed on the ’798 patent. The district court upheld the ’798 patent. However, the Eighth Circuit court of appeals reversed, finding that the improvements described in the ’798 patent were obvious improvements on the ’811 patent and other patents intended to protect plows from subsurface obstructions. Therefore, the Eighth Circuit held that the ’798 patent was invalid. Separately, Baxter Scoggin developed an insecticide-sprayer part that was patented by Cook Chemical (defendant). Competitors sued to invalidate this patent as obvious. The district court and Eighth Circuit found that the patent was valid. The Supreme Court granted certiorari in both cases.
Rule of Law
Issue
Holding and Reasoning (Clark, J.)
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