Lueddecke v. Chevrolet Motor Co.

70 F.2d 345 (1934)

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Lueddecke v. Chevrolet Motor Co.

United States Court of Appeals for the Eighth Circuit
70 F.2d 345 (1934)

Facts

H.W. Lueddecke (plaintiff) sent a letter to Chevrolet Motor Company (Chevy) (defendant), offering to provide details of a design change for Chevy’s vehicles that would fix a pervasive problem and save Chevy millions of dollars. In his proposal, Lueddecke requested that Chevy make an offer of payment and stated that he would provide complete details if he found the offer satisfactory. Chevy responded by stating Chevy’s policy of not making any agreements regarding invention proposals until sufficient details of the invention had been provided for examination. Chevy did not make an offer and instead invited Lueddecke to provide drawings and designs so that Chevy could determine whether Lueddecke’s ideas were of value. Lueddecke responded by identifying the problem mentioned in his proposal, which was the tendency of Chevy vehicles to lean to one side after several years of use, and proffered his solution of either moving some of the internal parts to the lighter side of the car or providing extra springs on the driver’s side of the car. Lueddecke did not provide any designs or drawings in support of his suggestions. Chevy responded with a letter, thanking Lueddecke for his interest and declining to enter into any agreement relating to Lueddecke’s ideas. Lueddecke subsequently brought a lawsuit against Chevy for appropriation of his ideas, claiming that an implied contract existed between the two parties and that Chevy implemented Lueddecke’s ideas into nearly all of the vehicles that Chevy manufactured after receiving Lueddecke’s letters. The trial court found for Chevy and dismissed the claims. Lueddecke appealed the decision.

Rule of Law

Issue

Holding and Reasoning (Woodrough, J.)

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