Supreme Court of the United States
Cardinal Chemical Co. v. Morton International, Inc.
May 17, 1993508 U.S. 83
Summary
The Court held that the Federal Circuit's affirmance of patent noninfringement does not moot an independently supported declaratory judgment counterclaim challenging patent validity. It further held that noninfringement alone does not justify routinely vacating validity judgments and that refusing to decide validity in this case would be an abuse of discretion. The Court vacated the Federal Circuit's judgment and remanded. Justice Stevens wrote for a unanimous Court in Parts I–III and for seven Justices in Part IV. Justice Scalia, joined by Justice Souter, concurred in part and in the judgment: they agreed that the validity controversy was not moot but would not decide whether other discretionary grounds could support the Federal Circuit's practice without adversarial briefing.
Holding
- Whether affirming noninfringement moots an independently supported declaratory judgment counterclaim concerning patent validity.. Affirmance of noninfringement does not itself moot the validity counterclaim or deprive the Federal Circuit of jurisdiction to review the declaratory judgment.
- The burden of demonstrating mootness after jurisdiction has been established.. Once jurisdiction is established, its continuation may be presumed absent further information; the party asserting mootness must identify subsequent events that ended the controversy.
- Whether noninfringement alone permits routine vacatur of patent-validity declaratory judgments.. Noninfringement alone does not justify vacating a validity determination, and refusing to decide validity on this record would be an abuse of discretion.
- Whether agreement on the question presented eliminates Article III adverseness.. The parties' agreement that the Federal Circuit's practice was erroneous did not eliminate the controversy because they remained opposed on the underlying validity of the patents.
Docket 92-114
Cited authorities
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