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Case Summaries

Contracts

[03/11] Lab. Corp. of Am. Holdings v. Metabolite Labs., Inc.
In an action for a declaratory judgment that plaintiff did not breach a license agreement for failure to pay know-how royalties on homocysteine assays performed after judgment had been entered in a prior patent infringement and breach of contract action, defendant's appeal from summary judgment for plaintiff is transferred to the Tenth Circuit as: 1) the present cause of action does not arise under federal patent law nor does defendant's right to relief necessarily depend on resolution of a substantial question of federal patent law, and thus, this court does not have jurisdiction over the appeal; and 2) this action is a state law contract dispute over know-how royalties brought pursuant to the district court's diversity jurisdiction.

[03/11] Griswold v. Cty. of Hillsborough
In an action by plaintiff, a disabled veteran, claiming that defendants violated his rights under the Veterans Benefits Act of 2003 by interfering with plaintiff's businesses' ability to obtain certain government contracts, dismissal of the complaint is affirmed where plaintiff's claims were barred under the doctrine of res judicata due to earlier litigation brought by plaintiff's companies arising from the same facts.

[03/10] Abdelhamid v. Fire Ins. Exch.
In homeowner's action against her insurance company after it denied coverage to her for the fire that burned her house down, summary judgment in favor of the insurance company is affirmed as the trial court did not err in granting summary judgment on the breach of contract claim as plaintiff's failure to comply constituted material breach of her contractual duties.

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Injury & Tort Law

[03/11] Griswold v. Cty. of Hillsborough
In an action by plaintiff, a disabled veteran, claiming that defendants violated his rights under the Veterans Benefits Act of 2003 by interfering with plaintiff's businesses' ability to obtain certain government contracts, dismissal of the complaint is affirmed where plaintiff's claims were barred under the doctrine of res judicata due to earlier litigation brought by plaintiff's companies arising from the same facts.

[03/11] Rehberg v. Paulk
In an action for malicious prosecution, retaliatory investigation and prosecution, and evidence fabrication, a denial of defendants' motion to dismiss based on absolute and qualified immunity is affirmed in part where plaintiff sufficiently alleged the requisite retaliatory motive, absence of probable cause, and but-for causation to state a retaliatory prosecution claim. However, the order is reversed in part where: 1) even if defendants knew one defendant's testimony before a grand jury was false, they still received absolute immunity for the act of testifying to the grand jury; and 2) plaintiff's voluntary delivery of emails to third parties constituted a voluntary relinquishment of the right to privacy in that information.

[03/10] Cameron v. N.Y.
In an action for false arrest and malicious prosecution, judgment for defendant-officers is reversed where: 1) prosecutors' opinions as to probable cause and complaining officers' credibility are irrelevant in virtually all cases involving claims of malicious prosecution; and 2) the introduction of such evidence was not harmless because it provided strong external validation for propositions that otherwise would have come in only from the defendants' mouths.

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Landlord Tenant

[03/03] Fed. Ins. Co. v. Commerce Ins. Co.
In plaintiff-insurance company's subrogation claim, district court's grant of summary judgment in favor of defendants in concluding that the implied coinsured doctrine controlled the outcome in this case and precluded the plaintiff from pursuing a subrogation claim is affirmed as plaintiff has not met its burden of proving that the "Responsibility for Damages" provision of a Residence and Care Agreement (RCA) overcomes the presumption that the landlord's insurance is held for the mutual benefit of both parties.

[02/09] Chacon v. Litke
In a wrongful eviction action, judgment in favor of plaintiffs-tenants concluding that defendants violated the San Francisco Rent Stabilization and Arbitration Ordinance is affirmed where: 1) defendants' interpretation of the Ordinance as conditioning a tenant's right to reoccupy the unit upon compliance with a 60-day notice is rejected; 2) substantial evidence supports the trial court's finding that the stipulation gave defendants temporary possession of the apartment for up to three months to make repairs and the plaintiffs retained their rights under the Ordinance to reoccupy the premises; 3) the litigation privilege did not apply to defendant's conduct in refusing to allow the plaintiffs to reoccupy the apartment; 4) trial court did not err in granting judgment on the pleadings on the affirmative defenses; and 5) trial court did not abuse its discretion in awarding plaintiffs' attorney's fees.

[02/01] Woodlands Park Mgmt., LLC. v. City of E. Palo Alto Rent Stabilization Bd.
Trial court's holding that the Rent Stabilization and Eviction for Good Cause Ordinance (RSO), adopted by the citizens of the City of East Palo Alto, permitted recovery of attorney fees by a landlord in successful litigation against the city is reversed as the intent of the electorate was that section 15.A.5 of the RSO authorize the recovery of attorney fees only in civil proceedings between landlords and tenants to enforce their respective rights under the RSO, and no other provision of the RSO provides for an award of fees against the city.

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Trade Secrets

[02/12] Ansys, Inc. v. Computational Dynamics N. Am., Ltd.
In plaintiff's suit against its former employee and his new employer (a competitor) claiming breach of noncompetition and confidentiality clauses in the employee's employment contract, interference with contractual relations, misappropriation of trade secrets, and unfair trade practices, denial of plaintiff's request for preliminary injunction to enforce the provisions of a one-year noncompetition clause in the employment agreement is affirmed as the district court did not abuse its discretion by finding that plaintiff has failed to make a showing of likelihood of success on the breach of contract claim, or a likelihood of irreparable injury.

[12/29] Jasmine Networks, Inc. v. Sup. Ct.
In plaintiff's action under the California Uniform Trade Secrets Act claiming that the defendants misappropriated certain trade secrets belonging to plaintiff, trial court's dismissal of the complaint on the ground that plaintiff had forfeited its standing to maintain an action for misappropriation when it had gone through bankruptcy proceedings shortly after filing the complaint is reversed where: 1) a current ownership requirement is not supported by general principles of property or tort law; 2) existing authority imposes no "current ownership requirement" on trade secret plaintiffs; 3) adoption of a current ownership requirement in trade secrets cases is not warranted by analogy to trademark, patent, or copyright law; and 4) no policy concern preponderates in favor of current ownership requirement.

[12/03] Ultimax Cement Mfg. Corp. v. CTS Cement Mfg. Corp.
In a patent infringement action involving patents related to rapid-hardening, high-strength cement, summary judgments finding noninfringement and that no trade secret was violated is affirmed in part, dismissed in part, vacated in part, reversed in part, and remanded where: 1) district court's finding of noninfringement is vacated and remanded as the court erred in claim construction of the the term "soluble CaSo4 anhydride"; 2) district court's grant of summary judgment of laches is reversed and remanded relating to one patent as it was not clear that plaintiff knew or should have known of defendant's alleged infringement before it conducted discovery on another patent in 2002; 3) district court erred in granting summary judgment finding that one patent claim was indefinite; 4) plaintiffs' appeal with respect to one patent is dismissed as it waived the argument of its invalidity; 5) denial of plaintiffs' motion to amend their complaint is affirmed; 6) summary judgment finding no trade secret violations is affirmed; 7) the district court did not abuse its discretion in denying plaintiffs' motion to disqualify defendants' attorneys; and 8) the district court's decision on exceptional case status is vacated for further proceedings on remand.

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