Justia U.S. Federal Circuit Court of Appeals Opinion Summaries

Several small businesses and a coalition of states challenged a series of executive orders issued by the President that imposed new tariffs of unlimited duration on nearly all goods imported from most countries. These tariffs, referred to as the Trafficking Tariffs and Reciprocal Tariffs, were imposed in response to declared national emergencies related to drug trafficking and trade imbalances. The executive orders directed changes to the Harmonized Tariff Schedule of the United States, resulting in significant increases in import duties on products from Canada, Mexico, China, and other major trading partners.The plaintiffs filed suit in the United States Court of International Trade (CIT), arguing that the President exceeded his authority under the International Emergency Economic Powers Act (IEEPA) by imposing these tariffs. The CIT granted summary judgment in favor of the plaintiffs, holding that IEEPA did not authorize the President to impose the challenged tariffs and permanently enjoined their enforcement. The government appealed, and the Federal Circuit consolidated the cases, stayed the injunction pending appeal, and heard the matter en banc.The United States Court of Appeals for the Federal Circuit affirmed in part, holding that IEEPA’s grant of authority to “regulate” importation does not include the power to impose tariffs of the type and scope at issue. The court found that IEEPA does not mention tariffs, duties, or taxes, and contrasted it with other statutes where Congress has explicitly delegated tariff authority to the President with clear limitations. The court also concluded that the government’s interpretation would raise serious constitutional concerns under the major questions and non-delegation doctrines. The Federal Circuit affirmed the CIT’s declaratory judgment that the executive orders were invalid, but vacated the universal injunction and remanded for the CIT to reconsider the scope of injunctive relief in light of recent Supreme Court guidance. View "V.O.S. Selections, Inc. v. Trump" on Justia Law

The petitioner received a flu vaccine on November 1, 2017. Over a month later, he developed upper respiratory symptoms and, after several days, experienced sudden generalized weakness. He was diagnosed with Guillain-Barré Syndrome (GBS) and also found to have a bacterial infection (H. influenzae pneumonia). During his hospitalization, multiple treating physicians associated his GBS with his respiratory infection, and none suggested a link to the flu vaccine. Upon discharge, his diagnoses included both GBS and H. influenzae pneumonia.The petitioner filed a claim for compensation under the National Childhood Vaccine Injury Act in the United States Court of Federal Claims, alleging that the flu vaccine caused his GBS. The case was assigned to a special master, who found that although the petitioner established a prima facie case for vaccine causation, the government had shown by a preponderance of the evidence that the unrelated H. influenzae infection was the sole substantial factor causing the GBS. The special master explicitly excluded the vaccine as a causal factor. The petitioner sought review in the Court of Federal Claims, arguing that the special master erred in applying the burden of proof and in making certain factual findings. The Court of Federal Claims rejected these arguments and upheld the special master’s decision.On appeal, the United States Court of Appeals for the Federal Circuit reviewed the Claims Court’s decision de novo, applying the same standards of review. The Federal Circuit held that, in a Table case under the Vaccine Act, the government must prove by a preponderance of the evidence that a factor unrelated to the vaccine was the sole substantial cause of the injury, but need not disprove vaccine causation as if it had been affirmatively established. The court found that the special master’s findings were not arbitrary or capricious and that the correct legal standards were applied. The Federal Circuit affirmed the Claims Court’s decision denying compensation. View "WHITE v. HHS " on Justia Law

Global Health Solutions LLC and Marc Selner each filed patent applications in August 2017 for a method of preparing a wound treatment ointment containing nanodroplets of an aqueous biocide suspended in petrolatum jelly without emulsifiers. Selner filed his application four days before GHS, making him the first-filer under the America Invents Act (AIA) “first-inventor-to-file” system. GHS alleged that its founder, Bradley Burnam, conceived the invention and communicated it to Selner, who then derived the invention and filed first. Both parties agreed that their applications claimed the same invention, and the dispute centered on who conceived the invention and when.The United States Patent and Trademark Office, Patent Trial and Appeal Board (the Board) instituted a derivation proceeding. After reviewing evidence, including contemporaneous emails, the Board found that Burnam communicated the invention to Selner by 4:04 p.m. on February 14, 2014, but also found that Selner had independently conceived the invention earlier that same day, by 12:55 p.m. The Board determined that Selner did not derive the invention from Burnam and ruled in favor of Selner. GHS appealed, arguing that the Board erred in its evidentiary rulings, burden of proof allocation, and failure to require reduction to practice for conception, and also requested that Burnam be named a co-inventor.The United States Court of Appeals for the Federal Circuit reviewed the Board’s legal conclusions de novo and factual findings for substantial evidence. The court held that the Board’s focus on “first-to-invent” was harmless error, as Selner’s independent conception was dispositive under the AIA. The court found no reversible error in the Board’s evidentiary rulings, burden allocation, or treatment of reduction to practice. The court also held that GHS failed to properly preserve its request for correction of inventorship. The Board’s judgment for Selner was affirmed. View "GLOBAL HEALTH SOLUTIONS LLC v. SELNER " on Justia Law

Erik Brunetti applied to register the word “FUCK” as a trademark for various goods and services, including sunglasses, jewelry, bags, and retail store services. After initial refusals based on the mark being “immoral or scandalous”—a ground later found unconstitutional by the Supreme Court in Iancu v. Brunetti—the United States Patent and Trademark Office (PTO) reexamined the applications. The PTO’s examining attorney refused registration, finding that the term was a widely used, commonplace word that failed to function as a trademark because consumers would not perceive it as identifying the source of the goods or services.The Trademark Trial and Appeal Board (TTAB) affirmed the refusals, concluding that the mark did not serve as a source indicator. The Board reasoned that “FUCK” is an “all-purpose word” with many recognized meanings and is commonly used on similar goods by various sources, so it would not be seen by consumers as distinguishing Brunetti’s products from others. The Board also rejected Brunetti’s constitutional arguments and his reliance on other registered marks, stating that each application must be considered on its own merits.On appeal, the United States Court of Appeals for the Federal Circuit reviewed the Board’s decision under the standards of the Administrative Procedure Act. The court rejected most of Brunetti’s arguments but found that the Board failed to articulate a clear and rational standard for when an “all-purpose word” like “FUCK” can or cannot function as a trademark, especially given the existence of similar registered marks. The Federal Circuit vacated the Board’s decision and remanded for further proceedings, holding that the Board must provide a satisfactory explanation and coherent guidance for its actions. View "In Re BRUNETTI " on Justia Law

In this case, a group of pensioners from a multiemployer retirement fund governed by ERISA challenged the reduction of their pension benefits following the enactment of the Multiemployer Pension Reform Act of 2014 (MPRA). The MPRA allowed plan administrators to reduce benefits for current and future beneficiaries in order to prevent plan insolvency, subject to certain procedural safeguards and approval by the U.S. Department of the Treasury. The plaintiffs, who had vested rights to their pension benefits, argued that these reductions constituted an uncompensated taking under the Fifth Amendment.The United States Court of Federal Claims granted summary judgment in favor of the government. The Claims Court found that while the plaintiffs had a cognizable property interest in their vested pension benefits, the reduction of those benefits did not amount to a physical taking. Instead, the court analyzed the claim as a regulatory taking under the Penn Central framework and concluded that the economic impact, interference with investment-backed expectations, and the character of the government action did not support a finding of a taking.On appeal, the United States Court of Appeals for the Federal Circuit affirmed the Claims Court’s decision. The Federal Circuit held that the MPRA’s reduction of pension benefits was not a physical taking because the plaintiffs had only a contractual right to payment, not a property interest in the plan’s assets, and the government did not appropriate any specific property for itself or a third party. The court further held that, under the Penn Central test, the reduction did not constitute a regulatory taking, as the economic impact was not severe, the plaintiffs’ expectations were not unduly interfered with given the heavily regulated nature of pension plans, and the government action served a substantial public purpose. The judgment for the government was affirmed. View "KING v. US " on Justia Law

Several landowners in Colorado owned property subject to a railroad easement held by Great Western Railway of Colorado, LLC. The railroad line, originally used for transporting sugar beets, had fallen into disuse except for railcar storage. In 2008, Great Western sought permission from the Surface Transportation Board (STB) to abandon the line. The STB granted this request and issued a Notice of Interim Trail Use (NITU) to allow negotiations for possible interim recreational trail use. Negotiations failed, and the NITU expired. Instead of abandoning the line, Great Western repeatedly extended its abandonment authority and ultimately decided not to abandon the line, continuing to use it for storage and making some improvements.The landowners sued the United States in the United States Court of Federal Claims, alleging that the issuance of the NITU constituted a temporary taking under the Fifth Amendment. Both parties moved for summary judgment. The Claims Court granted summary judgment to the government, finding that the plaintiffs failed to prove that the NITU caused a taking. Specifically, the court determined that Great Western would not have abandoned the line at the time of the NITU, so the NITU did not delay the vesting of the landowners’ reversionary interests.On appeal, the United States Court of Appeals for the Federal Circuit reviewed the Claims Court’s decision de novo. The Federal Circuit affirmed, holding that to establish a compensable taking in a rails-to-trails case, plaintiffs must show that the issuance of the NITU caused a delay in abandonment that would have otherwise occurred, thereby postponing the vesting of their property interests. The court found that the evidence showed Great Western would not have abandoned the line regardless of the NITU, so causation was not established. The court also rejected arguments that state law abandonment or mere issuance of a NITU alone could establish a taking. The judgment for the government was affirmed. View "SAUER WEST LLC v. US " on Justia Law

The case concerns two patents related to methods for preparing DNA samples for sequencing, owned by Laboratory Corporation of America Holdings, Labcorp Genetics, Inc., and The General Hospital Corporation. The patents describe techniques for enriching specific regions of DNA to make sequencing more efficient, using various types of primers and adaptors. The dispute centers on whether certain DNA preparation kits sold by Qiagen and its affiliates infringe these patents, specifically regarding the design and function of the primers used in Qiagen’s kits.After the plaintiffs filed suit in the United States District Court for the District of Delaware, alleging infringement of both patents, the case proceeded to a jury trial. The jury found that Qiagen willfully infringed the asserted claims of both patents—under the doctrine of equivalents for one patent and literally for the other—and awarded the plaintiffs approximately $4.7 million in damages. The district court denied Qiagen’s renewed motion for judgment as a matter of law (JMOL) on non-infringement, invalidity, and damages, and also denied Qiagen’s alternative request for a new trial.On appeal, the United States Court of Appeals for the Federal Circuit reviewed the district court’s denial of JMOL de novo. The Federal Circuit held that there was insufficient evidence to support the jury’s findings of infringement for either patent. The court determined that the district court erred in allowing the jury to interpret the claim term “identical” as “identical to a portion,” and found that the evidence did not support infringement under the doctrine of equivalents or literal infringement as required by the patent claims and their constructions. As a result, the Federal Circuit reversed the district court’s denial of JMOL of non-infringement for both patents, and remanded with instructions to grant JMOL of non-infringement. View "LABORATORY CORPORATION OF AMERICA HOLDINGS v. QIAGEN SCIENCES, LLC " on Justia Law

Shareholders of Fannie Mae and Freddie Mac, acting derivatively on behalf of these entities, challenged the federal government’s actions following the 2008 financial crisis. After the housing market collapse, Congress passed the Housing and Economic Recovery Act of 2008 (HERA), creating the Federal Housing Finance Agency (FHFA) and authorizing it to act as conservator for the Enterprises. The FHFA placed both entities into conservatorship, and the U.S. Treasury entered into agreements to provide financial support in exchange for senior preferred stock and other rights. In 2012, a “net worth sweep” was implemented, redirecting nearly all profits from the Enterprises to the Treasury, effectively eliminating dividends for other shareholders. The plaintiffs, as preferred shareholders, alleged that this arrangement constituted an unconstitutional taking under the Fifth Amendment.The United States Court of Federal Claims previously reviewed the case and granted the government’s motion to dismiss. The Claims Court relied on the Federal Circuit’s prior decision in Fairholme Funds, Inc. v. United States, which held that, under HERA, the Enterprises lost any cognizable property interest necessary to support a takings claim because the FHFA, as conservator, had broad authority over the Enterprises’ assets. The Claims Court found the plaintiffs’ claims indistinguishable from those in Fairholme and dismissed them accordingly.On appeal, the United States Court of Appeals for the Federal Circuit reviewed the dismissal de novo. The court affirmed the Claims Court’s decision, holding that claim preclusion barred the plaintiffs’ derivative takings claims because the issues had already been litigated in Fairholme. The court rejected arguments that the prior representation was inadequate or that the Supreme Court’s subsequent decision in Tyler v. Hennepin County fundamentally changed takings law. The Federal Circuit concluded that Fairholme remained binding precedent and affirmed the dismissal. View "FISHER v. US " on Justia Law

Valeo North America imported T-series aluminum sheets from China and sought a determination from the U.S. Department of Commerce as to whether these products were subject to existing antidumping and countervailing duty orders on common alloy aluminum sheet from China. The dispute centered on whether Valeo’s T-series sheets, which have a manganese-based core but are not registered with the Aluminum Association, fell within the scope of the orders, which cover certain aluminum sheets “as designated by the Aluminum Association.” Valeo argued that only registered alloys were covered and that its heat-treated T-series sheets should be excluded.The United States Department of Commerce initially ruled that Valeo’s T-series sheets were within the scope of the orders, interpreting the language to include unregistered alloys with the relevant chemical composition. Valeo challenged this determination at the United States Court of International Trade, which found the scope language ambiguous and remanded the case for further explanation, particularly regarding the treatment of unregistered alloys and the impact of heat treatment. On remand, Commerce again found the scope language ambiguous, considered additional regulatory factors, and reaffirmed that Valeo’s products were covered. The Trade Court sustained this remand determination, and Valeo appealed.The United States Court of Appeals for the Federal Circuit reviewed the case de novo. It held that the language “as designated by the Aluminum Association” in the orders was ambiguous and did not unambiguously exclude unregistered alloys. The court found that Commerce’s analysis under the regulatory framework was supported by substantial evidence and that Valeo’s arguments regarding heat treatment and the timing of Customs instructions were unpersuasive. The Federal Circuit affirmed the Trade Court’s decision, upholding Commerce’s determination that Valeo’s T-series sheets are within the scope of the antidumping and countervailing duty orders. View "VALEO NORTH AMERICA, INC. v. US " on Justia Law

The dispute centers on a patent for a system that automates the adjustment of selectorized dumbbells using an electric motor. The patent describes a dumbbell with stacks of weight plates on each side, a handle, and a movable selector that, when positioned, couples different numbers of plates to the handle. The innovation lies in using an electric motor, operatively connected to the selector, to move it into the desired position based on user input, thereby automating the weight selection process and addressing safety and convenience issues present in prior manual systems.The United States District Court for the District of Utah reviewed the case after the defendant moved to dismiss the complaint, arguing that the asserted patent claims were ineligible under 35 U.S.C. § 101. The district court applied the Supreme Court’s two-step framework for patent eligibility and determined that all but one claim (claim 19) were directed to an abstract idea and implemented using generic components, thus failing the eligibility test. The court granted the motion to dismiss as to claims 1–18 and 20, but denied it for claim 19, finding that the parties had not sufficiently addressed its eligibility.On appeal, the United States Court of Appeals for the Federal Circuit reviewed the district court’s decision de novo. The Federal Circuit held that the relevant claims were not directed to an abstract idea but instead to a specific mechanical improvement in selectorized dumbbells. The court found that the claims recited a sufficiently specific structure and method, including the use of an electric motor to automate weight selection, and thus did not preempt all forms of automated weight adjustment. The Federal Circuit reversed the district court’s dismissal of claims 1–18 and 20 and remanded the case for further proceedings. View "POWERBLOCK HOLDINGS, INC. v. IFIT, INC. " on Justia Law