Cites Rogers Locomotive & MacHine Works v. Kelley — Kelly v. Roberts (40 N. V. 433), A. K. Bank v. F. N. Bank (46 id. 82) distinguished. Rogers L. & M. Works v. Kelly et al. (19 Hun, 399) reversed.
Affiliations
Supreme Court of the United States — appointed by Chester Arthur
The case concerned a dispute over customs duties on imported old india-rubber shoes, invoiced as rubber scrap, where the collector assessed 25% ad valorem duty under the 1883 tariff act as articles composed of india-rubber, and the importer protested claiming exemption as similar to crude rubber on the free list. The Supreme Court affirmed the circuit court's judgment for the importer, holding that the goods were not dutiable because their only commercial value came from the rubber content usable like crude rubber, with no added value from prior manufacture. The core reasoning applied the similitude clause in Revised Statutes section 2499, under which non-enumerated articles similar in material, quality, texture, and use to free-list items are exempt from duty, as confirmed by uncontradicted evidence that the worn-out shoes had lost value as manufactured articles and fit the description of old scrap rubber for remanufacture.
This case was a patent infringement dispute in which the plaintiffs, holders of exclusive rights to a pipe patent in Connecticut, sued the defendant, an assignee with rights in Michigan, for selling and shipping pipes from Michigan that were intended for use in Connecticut. The lower court ruled for the defendant based on the precedent in Adams v. Burke, and the Supreme Court affirmed. The Court held that the sale was lawfully completed in Michigan and that neither the intended out-of-territory use nor the defendant's knowledge of it created infringement liability. The core reasoning was that a valid sale within an assignee's territory conveys unrestricted rights to use the item everywhere, as the patentee receives full consideration at sale and must protect territorial limits through contractual conditions rather than infringement suits against lawful sellers.
This case involved a patent infringement suit in equity brought by the Underwoods against Gerber and Andreas in the U.S. Circuit Court for the Eastern District of New York, alleging infringement of U.S. Patent No. 348,073 for a reproducing transfer surface used in place of carbon paper for typewriting or writing copies. The patent described a dye-based composition applied to paper, but the plaintiffs held a related patent (No. 348,072) on the underlying composition itself, which was not asserted here. The Circuit Court dismissed the bill, and the Supreme Court affirmed, holding that the composition of matter described but not claimed in the companion patent was dedicated to the public under precedents such as Miller v. Brass Co. and Mahn v. Harwood; therefore, merely coating paper with the known composition involved no patentable novelty or invention. The defendants' product matched the composition from the unasserted patent combined with paper as described in the sued-on patent.
This case was a creditors' bill in equity brought by the assignee in bankruptcy of David M. Smith against Smith and several transferees to set aside three conveyances of real property made in 1874 as fraudulent. The bill was filed in 1886, after Smith had been adjudged bankrupt in 1878 and discharged in 1879. The Circuit Court dismissed the bill, and the Supreme Court affirmed, applying New York's six-year statute of limitations for fraud actions and the two-year federal bankruptcy limitation in Revised Statutes § 5057. The court reasoned that the right of action belonged originally to creditors rather than the bankrupt, that the assignee therefore claimed under the creditors, and that the recorded deeds plus a related public lawsuit meant the fraud was or should have been discoverable well before the suit was filed, with no affirmative concealment shown to toll either limitations period.
This admiralty case arose from a January 1886 collision in the Hudson River between the British steamship Servia and the Belgian steamship Noordland, both departing New York harbor slips bound for sea. The master of the Noordland sued the Servia in rem for damages in the Southern District of New York; the Servia filed a cross-libel. After trial, the District Court dismissed the Noordland's libel, finding the Servia faultless and the collision due to the Noordland's delay in starting her engines ahead. The Circuit Court affirmed on findings that the Noordland continued backing after signaling an intent to proceed, encroaching on the Servia's course, while the Servia had stopped and reversed engines appropriately under the circumstances. The Supreme Court affirmed, holding that the Noordland's unjustifiable delay constituted negligence under special circumstances requiring each vessel to monitor the other, and that the Servia had fulfilled her duties.
This case was a dispute over title and possession of approximately 4000 acres of land in Limestone County, Texas, originally part of an 11-league Spanish land grant, with the core conflict centering on the correct location of the southern boundary line of a 6000-acre tract and claims of adverse possession. The plaintiffs, Sarah B. Mexia and her husband, sued defendant T. J. Oliver in federal circuit court to recover the land, alleging ownership through a 1874 partition deed and long-acquiesced boundaries established in 1855. The Supreme Court reversed the circuit court's judgment in favor of the defendant and remanded for a new trial, holding that the lower court erred by admitting into evidence an invalid power of attorney from Mrs. Hammekin to her husband and a related deed, which under Texas law could not convey the wife's separate property without her proper acknowledgment. These evidentiary errors were deemed potentially prejudicial because they could have influenced the jury's findings on boundary acquiescence and title issues raised in the petition to try title.
