Markman v. Westview Instruments, Inc

Brief Fact Summary.

Markman sues Westview for patent infringement. During trial the interpretation of a complex term of art is decided by the judge instead of the jury to the dissatisfaction of the Plaintiff who appeals the ruling.

Synopsis of Rule of Law.

Because of the court’s training in complex issues and knowledge of written documents, it is competent to correctly, fairly, and uniformly make decisions relating to the interpretation of a term of art.

Facts.

Plaintiff Markman sued Defendant Westview for infringing its inventory control system, for use by dry cleaners, patent. After a jury verdict, Defendant Westview moved for judgement as a matter of law. The main issue was how to define the claim term “inventory”. The district court held that the claim construction is a matter of law for the court to decide and found non infringement of the patent, in favor of Defendants. Plaintiff Markman appealed and the court of appeals for the Federal Circuit upheld the decision en banc. Plaintiff Markman petitioned the Supreme Court for certiorari.

Issue.

In a patent case, is the interpretation of a term of art a question for the judge?

Held.

Yes, in a patent case the interpretation of a term of art is a question for the judge and is not subject to the Seventh Amendment’s guarantee to a jury trial. Judgement of the lower courts is affirmed.

Discussion.

1. The wording of the Seventh Amendment makes it clear that parties are entitled to a jury trial if either demands one.
2. But there are sometimes cases that have questions that are not suitable for jury resolution because of their technical nature.
3. These issues require a challenging application of law to fact that the court is best suited to complete.
4. In this case, the judge, not the jury, should decide the meaning of “inventory” because the court, due to its training, is more competent to interpret a term of art.
5. The holding below is affirmed.