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Federal Courts -
U. S. Supreme Court - February 28 - March 21, 2001
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Traffix Devices v. Mktg. Displays, No. 99-1571,
SUPREME COURT OF THE UNITED STATES, March 20, 2001, Decided
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Overview: Upon expiration of respondent's patents for a dual-spring mechanism to permit signs to withstand strong winds, petitioner copied the design and marketed its own sign stands. Respondent alleged that its mechanism acquired secondary meaning such that consumers associated the look of the dual-spring design with respondent, and that petitioner thus infringed respondent's trade dress. The United States Supreme Court held that any acquired secondary meaning was irrelevant, since trade dress protection was precluded by respondent's failure to sustain its burden of demonstrating that its design was not functional. Both the disclosure of the dual-spring design in the claims of the expired patents and respondent's prior patent infringement litigation indicated that the design provided a unique and useful mechanism to resist the force of the wind. Respondent's trade dress claim was thus precluded, since trade dress protection only extended to product features which were not functional.
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Circuit City Stores v. Adams, No. 99-1379,
SUPREME COURT OF THE UNITED STATES, March 21, 2001, Decided
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Overview: The lower court determined that the exemption provision inapplied to all contracts of employment, including petitioner's employment contract, whether or not he was engaged in transportation. Applying the maxim ejusdem generis, the Supreme Court concluded that the residual phrase "any other class of workers engaged in commerce" was to be read to give effect to the terms "seamen" and "railroad employees." Thus, the text of the Federal Arbitration Act (FAA),, foreclosed the construction adopted by the lower court. The better interpretation of, therefore, confined the exemption to transportation workers. The Supreme Court rejected respondent's argument that the phrase "engaged in commerce" should be interpreted broadly in light of Congress' understanding of its power when the FAA was adopted because such a variable standard ignored the reason why the phrase became a term of art in the first place. Moreover, it would have been unwieldy to deconstruct statutoryphrases depending upon the year of a particular statutory enactment.
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Egelhoff v. Egelhoff, No. 99-1529,
SUPREME COURT OF THE UNITED STATES, March 21, 2001, Decided
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Overview: While petitioner was married to the decedent, the decedent designated petitioner as the beneficiary under a life insurance policy and a pension plan, which were provided by the decedent's employer and governed by ERISA. Two months after petitioner and the decedent divorced, the decedent died intestate. Respondents, decedent's children by a previous marriage, sued petitioner in state court to recover the life insurance and pension plan proceeds based upon a state statute providing that the designation of a spouse as the beneficiary of a nonprobate asset was revoked automatically upon divorce. The state supreme court ruled in favor of respondents. On certiorari, the Court reversed the judgment. The Court determined that ERISA expressly pre-empted the statute to the extent it applied to ERISA plans because the statute directly conflicted with ERISA's requirements that plans be administered, and benefits be paid, in accordance with plan documents. In addition, the state statute interfered with nationally uniform plan administration, one of the principal goals of ERISA.
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Ferguson v. City of Charleston, No. 99-936,
SUPREME COURT OF THE UNITED STATES, March 21, 2001, Decided
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Overview: A state hospital implemented a policy setting forth procedures to be followed by hospital staff to identify pregnant patients suspected of drug abuse. Pursuant to the policy, hospital staff members tested pregnant patients for drug abuse and reported positive tests to the police. Petitioners, women who received obstetrical care at the hospital and who were arrested after testing positive for cocaine, sued respondents, alleging that the warrantless and allegedly nonconsensual drug tests were unconstitutional searches. The federal appellate court found the searches to be reasonable as a matter of law under the "special needs" doctrine. On certiorari, the court reversed the judgment. Given the primary purpose of the program, which was to use the threat of arrest and prosecution in order to force women into treatment, and given the extensive involvement of law enforcement officials at every stage of the policy, the case simply did not fit within the closely guarded category of "special needs." Therefore,'s general prohibition against nonconsensual, warrantless, and suspicionless searches necessarily applied to the policy.
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