Walter King Stapleton

This case concerned whether the methods of solving Rubik's Cube and Rubik's Revenge puzzles infringed claims 3-5 of U.S. Patent No. 3,655,201, which describe a general approach to restoring a preselected pattern by engaging eight cube pieces and rotating sets of them about axes. After remand from the Federal Circuit on the doctrine of equivalents, the court held that the puzzles infringed because they performed substantially the same function in substantially the same way to give substantially the same result as the claimed method. The core reasoning was that the patent claims a method as it appears to the puzzle user, with differences in the number of apparent pieces or engagement mechanisms not substantially altering the function, way, or result of randomizing and restoring the pattern through rotations about three axes.

business & regulatoryprocedure

This diversity case concerns two injured workers and one spouse who sued their employer's workers' compensation insurer, PMA, for repeatedly failing to pay or delaying payment of medical bills related to compensable industrial accidents. The plaintiffs sought remedies under Delaware workers' compensation statutes, including liquidated damages and attorneys' fees, as well as tort damages for breach of the duty of good faith and fair dealing and intentional infliction of emotional distress. PMA moved to dismiss for failure to state a claim and, alternatively, for summary judgment. The court granted the motion in part and denied it in part, holding that certain statutory remedies were available while limiting or precluding some common-law tort claims based on the exclusivity provisions of the workers' compensation system and the Delaware Unfair Trade Practices Act.

labor & employmenttorts & liabilitybusiness & regulatory

This case is a patent infringement action by Schering Corporation against Precision-Cosmet Co., Inc. concerning a gas-permeable hard contact lens made principally of tertiary butyl styrene. After a jury returned a verdict for Schering awarding $1,263,482 and finding the patent valid, the defendant moved for judgment notwithstanding the verdict or a new trial, while Schering sought enhanced damages, prejudgment interest, and attorney fees. The court denied the JNOV and new-trial motions, concluding that substantial evidence supported the jury's determination that the invention would not have been obvious to a person of ordinary skill in the art in light of the cited prior art. The court granted Schering's motions in part by doubling the damages, awarding prejudgment interest at the Treasury bill rate under 28 U.S.C. § 1961, and allowing reasonable attorney fees.

business & regulatoryprocedure

This case is a personal injury suit by a Florida citizen against Delaware corporations arising from a 1980 slip-and-fall at a McDonald’s restaurant in Germany; the plaintiff filed suit in Florida federal court in 1983 and the case was transferred to Delaware under 28 U.S.C. § 1406(a) for lack of personal jurisdiction. The defendants moved for summary judgment, asserting that Delaware’s two-year statute of limitations barred the claim. The court held that Delaware’s statute of limitations governs regardless of whether the transfer is characterized under § 1404(a) or § 1406(a), because the transferor court lacked personal jurisdiction over the defendants and therefore could not have applied Florida law. Accordingly, the action was time-barred.

proceduretorts & liability

This case involved railroad companies operating an intermodal facility in Delaware that sued the state Attorney General and environmental officials to block enforcement of the Delaware Noise Control Act and its regulations against noise from refrigerated trailers. The plaintiffs argued the state rules were preempted by the federal Noise Control Act of 1972. The court granted a preliminary injunction, finding a likelihood of success on the preemption claim because Congress intended to occupy the field of interstate railroad noise regulation, leaving no gap for state rules even on activities like refrigerated units not specifically addressed in federal standards. The decision rested on the federal statute's language, legislative history, and the absence of any EPA approval for state enforcement under the federal law's savings clause.

business & regulatoryenvironmentfederal power

This diversity case concerns plaintiff Robert Goffe’s claims against Stephen Blake, AMW, Inc., and Avanti Motor Corporation for breach of an oral and written pre-incorporation agreement, common-law fraud, and breach of fiduciary duty arising from services allegedly performed to help acquire Avanti Motor Corporation. After denying dismissal as to two defendants and finding venue improper as to Blake, the court addressed competing transfer motions. It granted Goffe’s motion under 28 U.S.C. § 1406(a) to transfer the action to the District of Columbia, holding that personal jurisdiction existed over all defendants there because Avanti’s contacts satisfied the D.C. long-arm statute and the claims arose from those contacts; it denied the defendants’ competing motion under 28 U.S.C. § 1404(a) to transfer to the Northern District of Indiana. The core reasoning was that the interest of justice favored transfer to D.C.—where the key meetings, incorporation, and services occurred and where the plaintiff resides—rather than dismissal or transfer elsewhere, and that the acquisition-related evidence in Indiana was not central enough to override that conclusion.

procedurebusiness & regulatory

This case arose from contractual disputes and delays in constructing an addition to a children's hospital, leading to breach of contract claims by subcontractors Pierce and Dynalectric against prime contractor Gilbane, followed by counterclaims and third-party claims involving owner Nemours and other parties. The court considered Nemours' motions to dismiss the subcontractors' counterclaims. It held that Dynalectric's counterclaim against Nemours was within the court's ancillary jurisdiction because it qualified as a compulsory counterclaim under Fed. R. Civ. P. 13(a), as it arose from the same transaction or occurrence as Nemours' claims. The court also denied dismissal of the tortious interference with contractual relations claims, ruling that whether Nemours' conduct was justified is an affirmative defense that cannot be resolved on a motion to dismiss without further factual development.

procedurebusiness & regulatory

This case was a patent infringement action in which Mannesmann Demag Corporation sued Engineered Metal Products Company for infringement, induced infringement, and contributory infringement of U.S. Patent No. 4,207,060 covering a water-cooled pipe coil vessel design for electric arc furnaces used to melt scrap metal into steel; EMPCO denied infringement and counterclaimed for a declaratory judgment of invalidity. The court made findings of fact and conclusions of law on validity and infringement after describing the technology, the patent's claimed features such as contacting pipe sections arranged to form an interior wall with optional prominences for slag adherence, and the accused panels' eccentric pipe spacing, gaps, slag-stopper bars, and backbone supports. Core reasoning involved comparing the patent specifications and drawings to the structure and operation of the accused devices, including evidence of gaps exceeding tolerances, selective welding, and prior art references, to determine whether the claims were met literally or under the doctrine of equivalents.

business & regulatory

Artesian Water Company sued New Castle County under Section 107 of CERCLA to recover costs incurred in providing alternative drinking water sources after pollution from the County's landfill contaminated an aquifer used by Artesian's wells. The court granted the County's motion to dismiss the complaint without prejudice. The ruling rested on the determination that a prerequisite for such cost recovery is the existence of a state or federally approved cleanup plan consistent with the National Contingency Plan, grounded in the need for governmental oversight to ensure effective and fair remediation of hazardous substance releases.

environment

The case concerned a construction contract dispute arising from delays in completing a phase of the Alfred I. duPont Hospital project, where contractor DiSabatino sued owner Nemours for breach and negligence, and Nemours counterclaimed for liquidated damages plus indemnification for claims from other contractors affected by the delay. DiSabatino moved for partial summary judgment to cap its liability at the contract's liquidated damages provision of $500 per day beyond the December 20, 1980 substantial completion date. The court denied the motion, holding that while the contract liquidated damages for delay between the parties, it did not necessarily limit Nemours' recovery of actual damages or indemnification claims exceeding $15 million from follow-on contractors, as those third-party losses were not clearly covered by the clause. The court noted the parties had agreed to limit recovery for damages from missed deadlines to the daily rate but found the provision did not preclude the broader indemnification claims at issue.

business & regulatoryprocedure

This case was a declaratory judgment action brought by two Delaware corporations engaged in solid waste transportation against the Delaware Solid Waste Authority, seeking to enjoin enforcement of regulations that require all in-state generated solid waste to be disposed of only at Authority-operated or contracted facilities and impose documentation requirements on transfer stations. The plaintiffs alleged violations of the Commerce Clause and Equal Protection Clause, while the Authority moved to dismiss on Eleventh Amendment immunity, the Tax Injunction Act, failure to state a claim, and requested a stay for parallel state proceedings. The court held that the Authority was not immune under the Eleventh Amendment because it functions independently rather than as the state's alter ego, the Tax Injunction Act did not apply since the suit did not challenge the assessment or collection of a tax, and abstention was inappropriate, allowing the federal constitutional claims to proceed.

business & regulatoryenvironmentfederal powercivil rights

This case involved an employee, Jimmy Nanney, who sued his union (Local 1183 of the UAW) and employer (Chrysler) after a grievance over his discharge was settled with reinstatement and back pay but without the full vacation and holiday pay he believed he was owed under the collective bargaining agreement. Nanney claimed the union breached its duty of fair representation by improperly settling the grievance and that Chrysler violated the agreement, bringing the action under the Labor Management Relations Act. The court granted summary judgment to both defendants. It held that Nanney failed to exhaust the internal union remedies outlined in the union constitution before filing suit, and this failure also barred his claim against the employer since the union could have reactivated the grievance. The facts regarding his lack of appeal were undisputed, and no exception to the exhaustion requirement applied.

labor & employmentprocedure

Ralph Wheeler, an 18-year-old first-time inmate, sued three Delaware Department of Corrections officials under 42 U.S.C. § 1983 for alleged constitutional violations stemming from his 1980-1981 incarceration at the Delaware Correctional Center, including a sexual assault that occurred within hours of his arrival in a converted dormitory unit. The court conducted a bench trial and issued findings of fact detailing Wheeler's processing, interactions with inmates and guards, the layout and staffing of the Vo-Tech dorm, and the broader context of reported violence and sexual aggression at the facility. Evidence reviewed included 474 incidents of alleged homosexual and other violence from 1979-1981, of which only nine led to criminal prosecutions, along with internal investigations, staff responses, and patterns of underreporting by victims. The court analyzed whether prison officials exhibited deliberate indifference to inmate safety through policies on housing, supervision, and prosecution referrals, while distinguishing between reported incidents and staff reactions to them.

civil rightscriminal lawprocedure

This case is a patent infringement action brought by Moleculon Research Corporation, as assignee of inventor Larry Nichols' U.S. Patent No. 3,655,201, against CBS, Inc. as successor to Ideal Toy Corporation, concerning claims 3, 4, 5, 6, and 9 of the patent for a 2x2x2 cube puzzle that can be rotated in groups to randomize and restore colored faces. After severing damages issues, the court conducted a trial on validity and infringement, making findings of fact and conclusions of law based on the patent's preferred embodiment using magnets or mechanical means to hold eight smaller cubes together. The court rejected CBS's non-infringement arguments distinguishing Rubik's Cube and similar products, including claims that the puzzles do not involve exactly eight cubes or rotation about only two axes, because the patent claims use the open-ended term 'comprising' and are not limited to pure cubes or two axes; it also addressed contributory infringement and inducement through sales and instructions for solving the puzzles.

propertyprocedure

The case involved the EEOC suing the Delaware Department of Health and Social Services for alleged violations of the Equal Pay Act by paying lower wages to female employees than to male employees performing substantially equal work, seeking injunctive relief and back wages. The defendant moved to dismiss on the ground that the EEOC lacked authority to enforce the Act because the 1978 Reorganization Plan transferring such power from the Secretary of Labor was invalid under the Supreme Court's Chadha decision due to the one-house legislative veto provision in the Reorganization Act of 1977. The court examined whether that veto provision was severable from the remainder of the Act by assessing congressional intent through legislative history and statements, while noting the absence of a severability clause and conflicting rulings from other courts on the EEOC's enforcement authority.

labor & employmentfederal powercivil rights

This patent infringement case involved Austin Powder Company suing Atlas Powder Company over claims 25-27 of Austin's '621 reissue patent for a delayed primer device. The remaining issues addressed whether those claims were unenforceable due to Austin's counsel not submitting certain Atlas documents obtained in discovery to the PTO during reissue proceedings, whether Atlas's infringement was willful under 35 U.S.C. § 284, whether either party could claim an "exceptional case" under 35 U.S.C. § 285, and whether Atlas was entitled to intervening rights to continue manufacturing its Deckmaster product. The court reviewed the prosecution history of the original '296 patent and the reissue, including Rule 131 affidavits, submissions under Rule 97, and the timing of litigation notices to the PTO, while applying standards for inequitable conduct and the duty of candor. It made findings of fact on the parties' actions, the relevance of the withheld documents, and equitable considerations for protecting Atlas's business as of the reissue date.

business & regulatoryprocedure

This case involved a dispute under the Randolph-Sheppard Act, a federal program for licensing blind vendors to operate vending facilities on federal property, administered through state agencies like Delaware's Division for the Visually Impaired (D.V.I.). After D.V.I. awarded a lucrative vending spot to one applicant over another (Robert Albanese), an arbitration panel convened by the U.S. Department of Education ordered D.V.I. to pay Albanese compensatory damages for lost earnings and full attorney's fees. D.V.I. sued to challenge the award, arguing lack of statutory authority and sovereign immunity, with the federal defendant supporting that position. The court granted summary judgment to D.V.I., holding that the Act does not authorize arbitration panels to impose monetary damages or fees on state agencies, that sovereign immunity bars such remedies absent clear congressional waiver, and that participation in the program does not imply consent to them.

federal powercivil rightsprocedure

This case involved a patent dispute in which RCA sued Hazeltine and Lear Siegler for infringement of the Cole patent after the Federal Circuit reversed this court's earlier finding that the patent was invalid as anticipated by Dirks. The defendants sought to relitigate the infringement issue, arguing that the appellate court's claim construction differed from this court's and that the accused devices did not infringe under the new construction. The court held that the defendants were barred from relitigating infringement because they had a full opportunity to do so at trial, chose not to appeal the adverse infringement ruling, and could have raised non-infringement as an alternative ground on appeal. The court further concluded that its original infringement analysis remained consistent with the Federal Circuit's opinion on anticipation. As a result, the court granted RCA's request for an injunction against continued manufacture or sale of the infringing devices and denied a motion to join Esprit Systems as a party.

business & regulatoryprocedure

The case concerned whether Home Warranty Corporation's (HOW) insurance program qualified as a risk retention group under the federal Products Liability Risk Retention Act of 1981, which would exempt it from certain state insurance regulations enforced by Delaware's Insurance Commissioner. The court had previously ruled that the program's coverage for major structural defects in policy years three through ten constituted product liability coverage, and on renewed summary judgment motions, it addressed whether that coverage was HOW's "primary activity." Uncontested evidence showed that nearly three-quarters of HOW's risk exposure and the bulk of its losses occurred in those later years, with the first two years' builder warranty coverage being integral and necessary to the overall program. The Commissioner conceded that HOW's primary activity consisted of assuming and spreading product liability risks, leading the court to hold that HOW qualified as a risk retention group under the Act.

business & regulatoryfederal power

The case was a class action brought by Delaware AFDC recipients challenging reductions or terminations of their benefits under federal changes from the 1981 Omnibus Budget Reconciliation Act, which tied eligibility to 150 percent of the state's standard of need and deemed stepparent income available to the household. Plaintiffs alleged that Delaware's use of an outdated standard of need violated both federal AFDC requirements and state statutes mandating annual updates tied to the Title II index. The court addressed cross-motions for summary judgment, holding that any failure to update the standard constituted a violation of state law but did not deprive officials of authority to administer the program, and that federal courts could not grant relief on the state-law claims due to Eleventh Amendment constraints on suits against state officials.

federal powercivil rights