Hapgood v. Hewitt

119 U.S. 226 (1886)

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Hapgood v. Hewitt

United States Supreme Court
119 U.S. 226 (1886)

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Facts

Charles Hapgood (plaintiff) was president of manufacturing company Hapgood & Co. until 1880, when it dissolved. At the time of dissolution, Hapgood and two other people became trustees of the corporation. In 1873, Horace Hewitt (defendant) pitched himself to Hapgood as an expert in the manufacture and design of plows. Hapgood hired Hewitt as Hapgood & Co.’s vice president, and Hewitt purchased one share of stock. In 1874, Hewitt increased his interest in the company by buying half of Hapgood’s shares and also agreed to a new position as superintendent of the manufacturing department. In his new role, Hewitt agreed to use his best efforts to develop and make improvements to Hapgood & Co.’s plows, for which Hapgood & Co. paid him a salary. Hewitt did not expressly agree to exercise his inventing skills for Hapgood & Co.’s benefit or to assign patent rights to any of his inventions to his employer. At Hapgood’s request, Hewitt developed a new type of iron plow and supervised the creation of molds for Hapgood & Co. to manufacture the plow for sale. Hewitt left Hapgood & Co. in 1877 and sold his shares of the company back to Hapgood. In 1878, Hewitt applied for and obtained a patent for the iron plow. Hewitt then claimed that he had an exclusive right to manufacture the plow parts covered by the patent and threatened to sue Hapgood & Co. for infringement. Hapgood sued Hewitt on behalf of Hapgood & Co. and its successor company, seeking a decree directing Hewitt to assign the patent and all related rights to Hapgood & Co.’s successor company. The lower court ruled for Hewitt, finding that there was no agreement between Hapgood & Co. and Hewitt to assign Hewitt’s inventions to the corporation. Hapgood appealed.

Rule of Law

Issue

Holding and Reasoning (Blatchford, J.)

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