Crozier v. Fried. Krupp Aktiengesellschaft
Headline: Court bars patent injunction against an Army ordnance officer, holding Congress’s 1910 law gives patent owners a remedy in the Court of Claims and prevents stopping government gun manufacture.
Holding: The Court ruled that the patent suit against the Army officer must be dismissed because the 1910 statute gives patent owners a remedy against the United States in the Court of Claims, making an injunction to stop government manufacture inappropriate.
- Limits ability to get injunctions stopping military manufacturing of patented inventions.
- Directs patent owners to seek money compensation in the Court of Claims under 1910 law.
- Makes injunction relief unavailable while the Government’s statutory license and compensation process applies.
Summary
Background
A German corporation that owned three U.S. patents for improvements in guns and gun carriages sued William Crozier, the Army’s Chief of Ordnance, claiming he caused the manufacture and use of devices that infringed those patents at several arsenals. The parties filed a stipulation narrowing the case: the company waived claims for money, accounting, and a preliminary injunction, and the defendant acknowledged he directed government manufacturing of the disputed Model of 1902 field guns.
Reasoning
The Court considered whether an injunction could be issued to stop an Army officer from making or causing the manufacture of the patented devices. Since Congress had passed a 1910 law allowing patent owners to recover compensation from the United States in the Court of Claims when the Government uses a patented invention without a license, the Court held that the statute effectively provides the Government a license subject to compensation. Given that remedy, a permanent injunction to halt government manufacture would be improper or ineffective.
Real world impact
The Supreme Court reversed the lower appellate decision and dismissed the suit, but allowed the patent owner to pursue money compensation in the Court of Claims under the 1910 statute. That means patent owners asserting unlawful government use must follow the statutory claim process rather than seek injunctions to stop military production.
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