William Benner Enright

This case involved plaintiff Lockwood alleging that defendant American Airlines' SABREvision computer reservation system infringed his patent number '355, following earlier rulings of non-infringement on two other patents. The court considered cross-motions for summary judgment on infringement and a motion on the validity of the '355 patent. The court granted American's motions, finding no infringement because the SABREvision system is a manually operated enhancement to an existing reservation system that does not automatically generate tailored sales presentations as claimed in the patent. Additionally, the court determined the patent was invalid under 35 U.S.C. § 102(b) as it was not entitled to earlier filing dates from prior applications, making the 1986 patent prior art published more than one year before the effective filing date.

business & regulatorypropertyprocedure

This case involved a dispute over liability for soil and groundwater contamination from leaking underground gasoline storage tanks on a San Diego property that had previously operated as a gas station. Plaintiff First San Diego Properties, a subsequent purchaser that acquired the site in 1985 for use as a shopping center, sued prior owners and Exxon under the Resource Conservation and Recovery Act (RCRA) and related state laws after discovering extensive pollution in 1990. Exxon filed a counterclaim seeking contribution from the plaintiff as the current owner, alleging that the plaintiff's inaction after learning of the contamination made it jointly and severally liable. The court dismissed the amended counterclaim, holding that a subsequent purchaser who did not deposit additional waste and had no prior knowledge of the contamination cannot be deemed a contributor under RCRA's citizen-suit provisions merely by virtue of ownership. The decision distinguished this private contribution action from government-led suits and declined to extend passive liability to these facts.

environmentbusiness & regulatoryproperty

This case involves plaintiff Lockwood's patent infringement claims against American Airlines regarding two patents, the '115 and '359 patents, concerning certain devices or systems compared to the defendant's SABREvision technology. The court had previously granted summary judgment to the defendant on grounds of no literal infringement and inapplicability of the doctrine of equivalents due to prosecution history estoppel and lack of supporting equitable facts. Lockwood moved for reconsideration, citing new expert declarations, patent citation reports suggesting pioneering status, and arguments about equivalents in function-way-result and specific elements like payment acceptance and transportability. The court denied the motion, finding the additional information insufficient to alter its prior conclusions that estoppel barred the doctrine and no equities justified its application, while also rejecting requests for sanctions.

business & regulatoryprocedure

This case involved two field investigators suing their employer, the Carpenters/Contractors Cooperation Committee, under the Fair Labor Standards Act (FLSA) for unpaid overtime compensation after working more than forty hours in certain weeks. The court granted partial summary judgment to the plaintiffs, ruling that they were not exempt from overtime requirements under the administrative exemption. The decision rested on findings that the plaintiffs failed both the salary test, as their compensation was subject to hourly calculations and potential deductions, and the duties test, because they performed production work rather than administrative duties involving discretion and management policies. The court also struck the defendant's laches defense as inapplicable under the FLSA, imposed Rule 11 sanctions, and awarded attorneys' fees.

labor & employmentfederal power

This case was a patent infringement action in which Sure-Safe Industries and Intertrack Management sued C & R Pier Manufacturing, its president, and a former shareholder, alleging that the defendants' mobile home support products infringed U.S. Patent No. 4,937,989, which claims a combination of piers, a two-part I-beam clamp, and a tie-rod marriage lock assembly. The district court granted summary judgment for the defendants after finding no infringement, because the accused products did not contain all claimed elements and there was no evidence of the required direct physical connection or assembly between the piers and tie-rods. The court later denied the plaintiffs' motion for reconsideration, ruling that they had not shown new facts or circumstances, had produced no direct or sufficient circumstantial evidence of infringing use, and that their arguments contradicted the patent's own inventor testimony; it also denied related requests for Rule 54(b) certification and a stay pending appeal, citing the need for a complete factual record and the lack of demonstrated urgency.

business & regulatoryprocedure

This case is a patent infringement action in which inventor Lockwood sued American Airlines, alleging that its SABREvision enhancement to the Sabre reservation system infringed two patents on self-service interactive audiovisual terminals for dispensing information, goods, and services. The district court granted American's motion for summary judgment of non-infringement. The court reasoned that the patents claim fully automated, self-contained machines providing direct customer interaction via motion video and audio to simulate personal interviews, while SABREvision is a manually operated system used exclusively by travel agents that displays only still images without sound and accepts no direct customer input. Claim terms were given their ordinary meanings based on the patent specifications and prosecution history, with no genuine issues of material fact shown.

propertyprocedure

This case involves a patent infringement action brought by Sure Safe Industries and Intertrack against C & R Pier Mfg. and others over U.S. Patent No. 4,937,989, which covers a mobile home support system combining piers, a marriage lock clamp, and a tie-rod assembly. The court had previously granted summary judgment to defendants on non-infringement grounds. Defendants then sought a ruling on their invalidity counterclaims, citing Supreme Court guidance from Cardinal Chemical Co. v. Morton International. The court denied summary judgment on invalidity, finding genuine issues of material fact regarding whether the best mode was disclosed (specifically, a welded versus threaded tie-rod) and determining that the inventor's failure to review the application before signing the oath did not warrant invalidation absent fraud or deception.

propertyprocedure

This case involves a patent infringement suit brought by SureSafe Industries and Intertrack against C & R Pier Mfg., its president, and a former shareholder, alleging that defendants' mobile home support products infringed U.S. Patent No. 4,937,989, which claims a specific combination of piers, a two-part I-beam clamp (marriage lock), and a tie-rod assembly. The district court granted defendants' motions for summary judgment on noninfringement and for the individual defendant Chuck Giles. The court reasoned that the patent covers only the complete combination of all three subassemblies and does not claim any component individually, that defendants sold piers, clamps, and tie-rods separately without providing the full infringing combination, and that plaintiffs presented no evidence that Giles personally made, used, or sold any infringing product.

business & regulatoryprocedure

The case involved Brooktree suing AMD for patent and mask work infringement related to semiconductor chips used in computer graphics. A jury found AMD liable on most claims, determined the infringement willful, and awarded over $25 million in damages. In this post-trial decision, the court awarded Brooktree $744,600 in prejudgment interest on the patent claims after finding the damages could be segregated with sufficient certainty, granted a stay of execution conditioned on AMD posting real property security valued at twice the award, and issued a permanent injunction based on Brooktree's proposed language covering the infringing circuitry and mask works.

business & regulatoryprocedure

This consolidated class action and shareholder derivative suit alleged that MDC Holdings, its underwriter Drexel Burnham Lambert, accountant Touche Ross, and various individuals made materially false and misleading public statements about MDC's financial performance and prospects, artificially inflating the price of its securities from April 1985 to April 1989 in violation of federal securities laws including Section 10(b) and state common law claims for fraud and negligent misrepresentation. The court granted the foreign Drexel defendants' motion to dismiss for lack of personal jurisdiction, granted the individual Drexel defendants' motions to dismiss certain counts for failure to satisfy Rule 9(b) particularity requirements and Rule 12(b)(6) for inadequate aider-and-abettor or control-person liability allegations, denied Touche's motion to dismiss on Rule 9(b) grounds but granted dismissal of the Section 18 claim for lack of actual reliance pleading, and certified a class of all persons who purchased MDC securities during the period and suffered losses. The court reasoned that the foreign entities lacked sufficient contacts with the forum, that fraud claims against individuals required more specific factual allegations of their direct involvement, and that common questions of law and fact predominated over individual issues making a class action the superior method for adjudication.

business & regulatoryprocedure

The case involved Brooktree suing competitor AMD for infringement of its patents and mask works on semiconductor chips used in computer graphic displays. After a jury trial, AMD was found liable on nearly all patent and mask work claims, with the infringement deemed willful, resulting in a damages award exceeding $25 million. AMD moved for judgment notwithstanding the verdict or a new trial, arguing invalidity of the patents, non-infringement, failure to prove lack of reverse engineering under the Chip Protection Act, and excessive lost profits, while Brooktree sought enhanced damages, attorney fees, and prejudgment interest. The court denied AMD's JNOV and new trial motions, determining that reasonable jurors could have reached the verdicts based on the evidence presented, and denied Brooktree's requests for enhanced damages and fees but granted conditional prejudgment interest under the patent statute if damages could be properly allocated.

business & regulatory

This case is a proposed class action brought by investors in a limited partnership formed to restore the U.S. Grant Hotel in San Diego, alleging that multiple defendants—including the general partner Sybedon, underwriters like Prudential-Bache, accountants, appraisers, and insurers—made material omissions and overstated the project's financial prospects in violation of federal securities laws and related claims. After partial settlements removed some defendants and narrowed the issues, the court addressed motions to dismiss various causes of action in the second amended complaint, for class certification, for summary judgment, and for sanctions. The court granted class certification, finding the proposed representatives and counsel adequate, dismissed certain claims with prejudice against specific defendants such as National Union and Wilrock for insufficient pleading, denied other dismissal motions, and denied summary judgment and sanctions because genuine issues of material fact remained and the complaint was not sanctionably deficient. These rulings were based on the sufficiency of the allegations, the impact of prior settlements, and the need for further proceedings on the remaining claims.

business & regulatoryprocedure

In this case, Brooktree Corporation sued competitor Advanced Micro Devices (AMD) under the Mask Work Act, alleging that AMD had pirated two of its semiconductor chip designs used in computer graphics displays and was selling them at lower prices to recapture market share. Brooktree sought a preliminary injunction to stop the alleged infringement, claiming irreparable harm to its business and profitability. The court denied the motion, finding that Brooktree failed to demonstrate a likelihood of success on the merits because AMD's chips appeared to result from independent development rather than copying, that monetary damages would suffice for any harm shown, and that the balance of hardships did not tip sharply in Brooktree's favor.

business & regulatoryproperty

This case is a proposed class action by investor Robert Lubin against numerous defendants involved in the financing and renovation of the U.S. Grant Hotel, alleging material misstatements and omissions that fraudulently exaggerated the project's prospects in the sale of $43 million in limited partnership interests. The defendants include the developer, general partner, brokers, underwriters, accountants, appraisers, lawyers, and lenders, with claims brought under federal securities laws and California blue sky statutes. Various defendants moved to dismiss the First Amended Complaint and strike portions thereof for insufficient particularity in pleading fraud and other deficiencies, while Lubin moved for class certification and other investors sought to intervene as plaintiffs. The court granted intervention, dismissed certain claims against specific defendants for lack of particularized allegations or improper control-person liability, and deferred on class certification and counsel adequacy pending further argument.

business & regulatoryprocedure

In United States v. Ruiz-Villanueva, defendants moved to declare unconstitutional the sentencing guidelines promulgated by the United States Sentencing Commission under the Sentencing Reform Act of 1984, which established ranges of allowable sentences for federal crimes to reduce disparities and promote certainty while preserving some judicial flexibility. The court denied the motions, finding the defendants' constitutional challenges without merit. The core reasoning was that Congress provided the Commission with extensive guidance through enumerated purposes and factors in the Act, such that any remaining policy choices did not amount to an improper delegation of legislative power, consistent with precedents like Yakus v. United States; the court also rejected related separation-of-powers claims concerning judicial salaries and guideline modifications.

criminal lawfederal powerprocedure

The case arose from a bankruptcy trustee's direct action against an insurer for refusing to pay a default judgment entered against its insured under a professional liability policy, based on claims of bad faith settlement practices under California Insurance Code section 790.03. The trustee sought discovery of the insurer's loss reserve information, related policies and procedures, and details of prior lawsuits alleging similar violations. The bankruptcy court granted the discovery motion over the insurer's objections. On appeal, the district court reversed, holding that loss reserves are established pursuant to statutory and regulatory requirements rather than insurer discretion, and therefore cannot fairly be treated as an admission of liability or an assessment of any particular claim's value.

business & regulatoryprocedure

This case involved former Western Union employees who sued Western Union, Supermail, and related entities in state court after their January 1986 terminations, alleging breach of the covenant of good faith and fair dealing, misrepresentation, intentional infliction of emotional distress, defamation, and age discrimination arising from the conversion of a Western Union office into a Supermail-operated agency. Western Union removed the action to federal court, asserting that the claims were preempted by section 301 of the Labor Management Relations Act because they implicated a collective bargaining agreement. The court denied remand as to the claims against Western Union, finding that plaintiffs' allegations were artfully pleaded to avoid federal jurisdiction and that Western Union remained subject to the collective bargaining agreement as a joint employer. The court granted remand as to the claims against Supermail, concluding that Supermail operated as a separate employer whose conduct did not arise under the collective bargaining agreement and therefore raised no federal question. The action was bifurcated, with the Western Union claims to proceed in federal court and the Supermail claims to return to state court.

labor & employmentprocedurefederal power

Nationwide Insurance filed a declaratory relief action against its insureds, the Kings, seeking a ruling that their homeowners policy did not require the insurer to defend or indemnify them in an underlying state court lawsuit brought by their condominium association. The underlying suit sought only injunctive and declaratory relief to enforce covenants requiring removal of a window air conditioner, and the state court ultimately granted an injunction with no award of damages. The federal district court granted summary judgment to Nationwide, holding that the policy expressly limited coverage to payment of damages the insureds were legally obligated to pay due to an occurrence, and that the underlying action presented no potential for such damages. The court rejected arguments that equitable relief could lead to future damages claims or that attorney fees constituted damages under the policy. It concluded there was no duty to defend where the policy's coverage obligations were limited to damages.

propertyprocedure

Donald Holland sued Bank of America and two supervisors, alleging breach of contract, breach of the implied covenant of good faith and fair dealing, and related misrepresentation claims after his demotion from branch manager, subsequent transfers, and placement on unpaid medical leave without restoration to prior roles; he also challenged the handling of his disability benefits under an employee plan. The U.S. District Court granted summary judgment to all defendants on every claim. The court concluded there was no evidence of an enforceable written or oral contract promising permanent employment or specific job protections, performance criticisms justified the bank's actions under any implied covenant, and ERISA claims regarding plan administration could not proceed against the bank because it had delegated fiduciary control to a separate committee.

labor & employmentprocedure

The case involved a former employee who sued her employer after being laid off, alleging breach of an implied employment contract for indefinite tenure absent good cause, tortious breach of the implied covenant of good faith and fair dealing, age discrimination, fraud, and negligent misrepresentation. The court granted the employer's motion for summary judgment on all five claims. It reasoned that the plaintiff failed to raise genuine issues of material fact on essential elements, including the existence of enforceable contract terms or fraudulent representations, that the layoff was supported by good cause due to a documented company-wide reduction in force amid declining orders, and that evidence did not support the discrimination or misrepresentation allegations.

labor & employmentcivil rightstorts & liability