The Supreme Court of the United States announced decisions in two cases this morning:
Global-Tech Appliances, Inc. v. SEB S.A., No. 10-6: After respondent obtained a patent for an innovative deep fryer, it sued a subsidiary of petitioner, claiming the sub had violated 35 U. S. C. §271(b) by actively inducing others to sell fryers in violation of respondent's patent rights. After granting review of a Federal Circuit decision upholding a judgment for respondent on the grounds that deliberate disregard of a known risk is a form of actual knowledge, the Court today held that induced infringement under §271(b) requires knowledge that the induced acts constitute patent infringement, and that deliberate indifference to a known risk that a patent exists does not satisfy the knowledge required by §271(b). The Court nonetheless concluded that the Federal Circuit’s judgment must be affirmed because the evidence was plainly sufficient to support a finding of knowledge under the doctrine of willful blindness.
The Court's decision is available here.
Ashcroft v. al-Kidd, No. 10-98: Respondent alleged that, after the September 11th attacks, then-Attorney General Ashcroft authorized federal officials to detain terrorism suspects using the federal material-witness statute,18 U. S. C. §3144. He claimed that this pretextual detention policy led to his material-witness arrest as he was boarding a plane to Saudi Arabia. The District Court denied Ashcroft’s motion to dismiss on immunity grounds, and the Ninth Circuit affirmed. The Court today reversed. It held that the objectively reasonable arrest and detention of a material witness pursuant to a validly obtained warrant cannot be challenged as unconstitutional on the basis of allegations that the arresting authority had an improper motive. Because respondent conceded that individualized suspicion supported the issuance of the material-witness arrest warrant, and did not assert that his arrest would have been unconstitutional absent the alleged pretext, the Court held there is no Fourth Amendment violation here, and that petitioner did not violate clearly established law.
The Court's decision is available here.
The Court also granted review in one case:
Perry v. New Hampshire, No. 10-8974: Whether Due Process protections against unreliable identification evidence apply to all identifications made under suggestive circumstances, as some courts have held, or only when the suggestive circumstances were orchestrated by the police?
The Supreme Court
May 31, 2011
