Russell v. Place

Nathan Russell (plaintiff) originally held a patent on leather preparation. The patent contained two claims, each containing a different process for treating leather. The initial patent was defective, because it did not adequately describe the invention. Russell corrected the description, and the patent was reissued. Russell sued Isaac Place and others (collectively, Place) (defendants), alleging that Place was infringing on Russell’s patent by using and selling the patented leather-treatment process without a license. As a defense, Place argued that Russell’s current patent was invalid. A jury found that Place had infringed on Russell’s patent and awarded damages. However, the record did not indicate whether the jury found that Place had infringed on the first claim in Russell’s patent, the second claim, or both claims. Later, Russell sued Place a second time, alleging that Place was still infringing on the same patent. As a defense, Place again argued that Russell’s patent was invalid. Russell claimed that the judgment in the first lawsuit had conclusively determined that the patent was valid and that this estopped or precluded Place from relitigating the issue of the patent’s validity in the second lawsuit. The court ruled for Place, finding that Place was not estopped from contesting the patent’s invalidity in the second lawsuit. Russell appealed directly to the United States Supreme Court.