Moore v. United States

Background

A toolmaker who worked as a wood-caulker at a navy yard sued the United States for pay after the Government used a tool he patented without a license. He said he conceived the tool before government service and finished the invention in May 1914 at home while off duty. He served in the navy yard from March 26, 1913, to July 16, 1914. He filed a suit under a 1910 law that allows payment when the Government uses a patented invention without permission.

Reasoning

The Court considered whether the 1910 law’s third proviso prevents recovery when an invention was discovered or completed while the inventor was employed by the Government. The Court read the statute plainly and concluded the proviso applies here because the inventor admitted completing the tool in May 1914 while still in government employment. The Court rejected the argument that working on the invention only outside official hours should change the outcome, saying that would effectively rewrite the statute.

Real world impact

The ruling means people who work for the federal Government generally cannot use this 1910 law to recover payment for devices they discovered or completed while employed, even if they did some work at home off duty. The decision affirms the Court of Claims’ dismissal and enforces the statutory exclusion as written. This outcome depends entirely on the statute’s language and the timing the inventor himself alleged.