Mississippi Chemical Corp. v. Swift Agricultural Chemicals Corp.
United States Court of Appeals for the Federal Circuit
717 F.2d 1374, 219 U.S.P.Q. 577 (1983)
- Written by Eric Miller, JD
Facts
Swift Agricultural Chemicals Corporation (Swift) (plaintiff) successfully sued Usamex Fertilizers, Inc., for infringement of a patent. Four years later, Swift brought an action against Farmland Industries, Inc., for infringement of the same patent. This time, the federal district court held that Swift’s patent was invalid on the ground of anticipation by prior art. However, before that decision was issued, Swift charged Mississippi Chemical Corporation (defendant) with infringement of the patent. After the case against Farmland Industries came to an end, Mississippi Chemical moved for summary judgment on the basis of the patent’s invalidity—in other words, an invocation of the doctrine of collateral estoppel. The federal district court judge denied the motion without requiring Swift to show fault with the previous judgment of invalidity. Mississippi Chemical then petitioned for a writ of mandamus directing the district court judge to grant the motion for summary judgment. The United States Court of Appeals for the Federal Circuit reviewed the petition.
Rule of Law
Issue
Holding and Reasoning (Friedman, J.)
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