Tate v. Scanlan International, Inc.

403 N.W.2d 666 (1987)

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Tate v. Scanlan International, Inc.

Minnesota Court of Appeals
403 N.W.2d 666 (1987)

Facts

Karen Tate (plaintiff), an operating nurse, conceived in 1978 of an idea to handle sutures, which were extremely delicate and subject to breakage when clamped in place during surgery. Nurses dealt with this problem by fitting pieces of cut catheter tubing over the clamp ends to protect sutures when in use. However, the tubing pieces were not radiopaque (visible with an x-ray), and it was difficult to account for the number of pieces cut. Tate conceived the idea of forming precut tips that would be easily accountable and constructed of radiopaque material. Scanlan International, Inc. (SII) (defendant) designed and marketed surgical supplies. In 1979, Tate met with Timothy Scanlan, SII’s president, to discuss her idea with an understanding that her idea would be kept confidential and that if SII decided to implement it, SII would compensate Tate. Scanlan later wrote Tate that he liked her idea and that SII would investigate it. In May 1981, SII launched a product implementing Tate’s idea under the trademark Suture Boots. There was no dispute that Tate did not design any aspect of the Suture Boots, but Tate asserted she had conceived of a system to help nurses both firmly handle and protect sutures during surgeries. Scanlan and Tate, however, were unable to agree on compensation terms. Tate sued SII for breach of express and implied contracts, unjust enrichment, conversion, and breach of confidence. During trial, Thomas McGoldrick, a medical-marketing expert, gave undisputed testimony that “concrete” in the medical field meant that the concept was very well defined, with reasonable access to all parts needed to develop the idea. McGoldrick also testified that a working model in this field was seldom presented. In special verdicts, the jury found that: (1) Tate’s idea was novel and concrete, (2) Tate had communicated her idea confidentially, (3) SII had agreed to compensate Tate for successfully using her idea, and (4) SII had breached its agreement. The jury awarded Tate over $500,000 in total damages. SII filed a motion for judgment notwithstanding the verdict (JNOV), but the court denied SII’s motion. SII appealed.

Rule of Law

Issue

Holding and Reasoning (Forsberg, J.)

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