Teets v. Chromalloy Gas Turbine Corp.

General Electric Aircraft Company (GE) engaged a division of Chromalloy Gas Turbine Corporation (Chromalloy) (defendant) called DRB Industries (DRB) to design a manufacturing process. GE had recently created a fuel-efficient turbine engine with lightweight fan blades. The blades were susceptible to breakage, and GE wanted each blade covered with a one-piece protective covering, referred to as a leading edge. GE hired DRB to design a method for manufacturing a leading edge; it requested that the edge be made from a single piece of titanium. In November 1991, Douglas R. Burnham, the general manager of DRB, made J. Michael Teets (plaintiff) chief engineer on the project. Teets was an at-will employee without a written employment contract. None of DRB’s early designs used a single piece, and its first design failed. During a meeting to address the first design’s failure, Teets revealed sketches he had made at home of a hot-forming process (HFP) that would produce a single-piece leading edge. With the approval of Burnham and the assistance of other DRB employees, Teets continued to develop the HFP at DRB while also working on DRB’s multipiece designs. In the summer of 1992, DRB’s multipiece designs failed again, but the HFP tested successfully. GE ordered the edges made using the HFP. In early 1993, Teets began working on a patent application for the HFP with DRB and Chromalloy; in the application, he identified Burnham as a co-inventor. However, later that year Teets began asserting sole ownership of the HFP, and in June 1993 he sued Chromalloy, seeking a declaration of ownership. At trial, the district court found Teets to be the sole owner of HFP. Chromalloy appealed.