Opinion · Supreme Court of the United States
Holmes Group, Inc. v. Vornado Air Circulation Systems, Inc.
535 U.S. 826
- Type
- Opinion
- Court
- Supreme Court of the United States
- Jurisdiction
- Federal
- Date
- 2002-06-03
- Topic
- general
How later courts describe this case
- holding that counterclaims cannot serve as the basis for federal jurisdiction under the well-pleaded complaint rule
- holding that a federal defense cannot establish federal jurisdiction, and also “declin[ing] to transform the longstanding well-pleaded-complaint rule into the ‘well-pleaded-complaint-or-counterclaim rule’ ”
- holding that neither a counterclaim nor an answer can serve as the basis for federal jurisdiction
- holding that a counterclaim cannot serve as the basis for “arising under” federal question jurisdiction
- holding that “a counterclaim—which appears as part of the defendant’s answer, not as part of the plaintiff’s complaint—cannot serve as the basis for ‘arising under’ jurisdiction”
- holding that “a counterclaim — which appears as part of the defendant’s answer, not as part of the plaintiffs complaint — cannot served as the basis for ‘arising under’ jurisdiction.”
- observing that the circulation of images that constitute child pornography causes continuing harm to the children portrayed
- holding that removal based on allegations in a counterclaim was improper
Citator
Holmes Group, Inc. v. Vornado Air Circulation Systems, Inc. is good law as far as the corpus records: followed by 1 later decision, and nothing recorded condemns it.
- Authority status
- positive
- Cited by
- 607 opinions
- Followed
- 1 times
delivered the opinion of the Court.
In this case, we address whether the Court of Appeals for the Federal Circuit has appellate jurisdiction over a case in which the complaint does not allege a claim arising under federal patent law, but the answer contains a patent-law counterclaim.
I
Respondent, Vornado Air Circulation Systems, Inc., is a manufacturer of patented fans and heaters. In late 1992,
Nevertheless, on November 26,1999, respondent lodged a complaint with the United States International Trade Commission against petitioner, The Holmes Group, Inc., claiming that petitioner’s sale of fans and heaters with a spiral grill design infringed respondent’s patent and the same trade dress held unprotectable in Vornado I. Several weeks later, petitioner filed this action against respondent in the United States District Court for the District of Kansas, seeking, inter alia, a declaratory judgment that its products did not infringe respondent’s trade dress and an injunction restraining respondent from accusing it of trade-dress infringement in promotional materials. Respondent’s answer asserted a compulsory counterclaim alleging patent infringement.
The District Court granted petitioner the declaratory judgment and injunction it sought. 93 F. Supp. 2d 1140 (Kan. 2000). The court explained that the collateral-estoppel effect of Vornado I precluded respondent from relit-igating its claim of trade-dress rights in the spiral grill design. It rejected respondent’s contention that an intervening Federal Circuit case, Midwest Industries, Inc. v. Karavan Trailers, Inc., 175 F. 3d 1356 (1999), which disagreed with the Tenth Circuit’s reasoning in Vornado I, constituted a change in the law of trade dress that warranted relitigation of respondent’s trade-dress claim. The court also stayed all proceedings related to respondent’s counterclaim, adding that the counterclaim would be dismissed if the declaratory judgment and injunction entered in favor of petitioner were affirmed on appeal.
II
Congress vested the Federal Circuit with exclusive jurisdiction over “an appeal from a final decision of a district court of the United States... if the jurisdiction of that court was based, in whole or in part, on [28 U. S. C. §] 1338 ....” 28 U. S. C. § 1295(a)(1) (emphasis added). Section 1338(a), in turn, provides in relevant part that “[t]he district courts shall have original jurisdiction of any civil action arising under any Act of Congress relating to patents ....” Thus, the Federal Circuit’s jurisdiction is fixed with reference to that of the district court, and turns on whether the action arises under federal patent law.1
Section 1338(a) uses the same operative language as 28 U. S. C. § 1331, the statute conferring general federal-question jurisdiction, which gives the district courts “original jurisdiction of all civil actions arising under the Constitution, laws, or treaties of the United States.” (Emphasis added.) We said in Christianson v. Colt Industries Operat
The well-pleaded-complaint rule has long governed whether a case “arises under” federal law for purposes of § 1331.2 See, e. g., Phillips Petroleum Co. v. Texaco Inc., 415 U. S. 125, 127-128 (1974) (per curiam). As “appropriately adapted to § 1338(a),” the well-pleaded-complaint rule provides that whether a case “arises under” patent law “must be determined from what necessarily appears in the plaintiff’s statement of his own claim in the bill or declaration . . . .” Christianson, 486 U. S., at 809 (internal quotation marks omitted). The plaintiff’s well-pleaded complaint must “establish] either that federal patent law creates the cause of action or that the plaintiff’s right to relief necessarily depends on resolution of a substantial question of federal patent law____” Ibid. Here, it is undisputed that petitioner’s well-pleaded complaint did not assert any claim arising under federal patent law. The Federal Circuit therefore erred in asserting jurisdiction over this appeal.
A
Respondent argues that the well-pleaded-complaint rule, properly understood, allows a counterclaim to serve as the basis for a district court’s “arising under” jurisdiction. We disagree.
Allowing a counterclaim to establish “arising under” jurisdiction would also contravene the longstanding policies underlying our precedents. First, since the plaintiff is “the master of the complaint,” the well-pleaded-complaint rule enables him, “by eschewing claims based on federal law,... to have the cause heard in state court.” Caterpillar Inc., supra, at 398-399. The rule proposed by respondent, in contrast, would leave acceptance or rejection of a state forum to the master of the counterclaim. It would allow a
For these reasons, we decline to transform the longstanding well-pleaded-complaint rule into the “well-pleaded-complaint-or-counterclaim rule” urged by respondent.
B
Respondent argues, in the alternative, that even if a counterclaim generally cannot establish the original “arising under” jurisdiction of a district court, we should interpret the phrase “arising under” differently in ascertaining the Federal Circuit’s jurisdiction. In respondent’s view, effectuating Congress’s goal of “promoting the uniformity of patent law,” Brief for Respondent 21, requires us to interpret §§ 1295(a)(1) and 1338(a) to confer exclusive appellate jurisdiction on the Federal Circuit whenever a patent-law counterclaim is raised.3
* * *
Not all cases involving a patent-law claim fall within the Federal Circuit’s jurisdiction. By limiting the Federal Circuit’s jurisdiction to cases in which district courts would have jurisdiction under § 1338, Congress referred to a well-established body of law that requires courts to consider whether a patent-law claim appears on the face of the plaintiff’s well-pleaded complaint. Because petitioner’s complaint did not include any claim based on patent law, we vacate the judgment of the Federal Circuit and remand the case with instructions to transfer the case to the Court of Appeals for the Tenth Circuit. See 28 U. S. C. § 1631.
It is so ordered.
Like Christianson v. Colt Industries Operating Corp., 486 U. S. 800, 814-815 (1988), this case does not call upon us to decide whether the Federal Circuit’s jurisdiction is fixed with reference to the complaint as initially filed or whether an actual or constructive amendment to the complaint raising a patent-law claim can provide the foundation for the Federal Circuit’s jurisdiction.
The well-pleaded-complaint rule also governs whether a case is removable from state to federal court pursuant to 28 U. S. C. § 1441(a), which provides in relevant part:
“Except as otherwise expressly provided by Act of Congress, any civil action brought in a State court of which the district courts of the United States have original jurisdiction, may be removed by the defendant or the defendants, to the district court of the United States for the district and division embracing the place where such action is pending.”
See Franchise Tax Bd. of Cal. v. Construction Laborers Vacation Trust for Southern Cal., 463 U. S. 1 (1983).
Echoing a variant of this argument, Justice Ginsburg contends that “giv[ing] effect” to Congress’s intention “to eliminate forum shopping and to advance uniformity in ... patent law” requires that the Federal Circuit have exclusive jurisdiction whenever a patent claim was “actually adjudicated.” Post, at 840 (opinion concurring in judgment). We rejected precisely this argument in Christianson, viz., the suggestion that the Federal
Although Justice Stevens agrees that a correct interpretation of § 1295(a)(1) does not allow a patent-law counterclaim to serve as the basis for the Federal Circuit’s jurisdiction, he nevertheless quibbles that “there is well-reasoned precedent” supporting the contrary conclusion. See post, at 835 (opinion concurring in part and concurring in judgment). There is not. The cases relied upon by Justice Stevens and by the court in Aerojet-General Corp. v. Machine Tool Works, Oerlikon-Buehrle Ltd., 895 F. 2d 736 (CA Fed. 1990), simply address whether a district court can retain jurisdiction over a counterclaim if the complaint (or a claim therein) is dismissed or if a jurisdictional defect in the complaint is identified. They do not even mention the well-pleaded-complaint rule that the statutory phrase “arising under” invokes. Nor do any of these cases interpret § 1295(a)(1) or another statute conferring appellate jurisdiction with reference to the jurisdiction of the district court. Thus, the cases relied upon by Justice Stevens have no bearing on whether the phrase “arising under” can be interpreted differently in ascertaining the jurisdiction of the Federal Circuit than that of the district court.