Cardinal Chemical Company v. Morton International, Inc. (1992)
- Docket
- 92-114
- Decided
- 1992-01-01
Summary
Question: Can a federal court, with exclusive jurisdiction over all federal appeals concerning patent litigation, use its finding that a patent has not been infringed as a per se justification for upholding the validity of the disputed patents themselves? Conclusion: No. In a unanimous decision, the Court held that two questions of law do not always necessarily cancel each other out when only one is resolved. The Court observed that in matters of patent law, noninfringement and invalidity are two separate questions. Therefore, the Court of Appeals for the Federal Circuit may find that a patent has not been infringed but it may not rely on such a determination as a per se basis for vacating a judgement holding the same patent invalid. Although the Court of Appeals' dogmatic practice existed since 1987, it was unsupported by the "case or controversy" requirement of Article III, and imposed undue burdens on those who remained convinced of the disputed patent's invalidity.