Standard Parts Co. v. Peck

264 U.S. 52 (1924)

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Standard Parts Co. v. Peck

United States Supreme Court
264 U.S. 52 (1924)

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Facts

William Peck (plaintiff) worked for Hess-Pontiac Spring & Axle Company (Pontiac), which was later bought by Standard Parts Co. (defendant). Peck worked subject to an employment agreement in which he agreed to devote his time to developing a process and machinery to produce a front spring for use in cars. Standard Parts agreed to pay Peck $300 per month, plus a bonus when the project was finished. Peck completed his work and obtained a patent for the process and machinery he created. Peck sued Standard Parts after it bought Pontiac, asserting that he had merely granted Pontiac a license to use his invention and that the license terminated when Standard Parts bought Pontiac. Standard Parts countered that it had purchased all of Pontiac’s assets, including the process and machinery Peck created and it was thus the rightful owner of the related patent. The district court found for Standard Parts, holding that an employee hired to invent an item or improve a process owes the employer the patent rights because he was merely doing what he was hired to do. Peck appealed. The court of appeals reversed, finding that Peck was the rightful patent owner and had merely given his employer a license. Standard Parts sought review from the United States Supreme Court.

Rule of Law

Issue

Holding and Reasoning (McKenna, J.)

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