Graham V. John Deere Co. - Facts and Procedural History

Facts and Procedural History

The case was actually a set of consolidated appeals of two cases, originating in the same court and dealing with similar issues. The named petitioner, William T. Graham, had sued the John Deere Co. for patent infringement. The invention in question was a combination of old mechanical elements: a device designed to absorb shock from the shanks of chisel plows as they plow through rocky soil and thus to prevent damage to the plow. Graham sought to solve this problem by attaching the plow shanks to spring clamps, to allow them to flex freely underneath the frame of the plow. He applied for a patent on this clamp, and in 1950, obtained U.S. Patent 2,493,811 (referred to by the Court as the '811 patent). Shortly thereafter, he made some improvements to the clamp design by placing the hinge plate beneath the plow shank rather than above it, in order to minimize the outward motion of the shank away from the plate. He applied for a patent on this improvement, which was granted in 1953 as U.S. Patent 2,627,798 (referred to by the court as the '798 patent). While Graham’s patent had been upheld in a previous case before the United States Court of Appeals for the Fifth Circuit, the United States Court of Appeals for the Eighth Circuit reversed the opinion of the United States District Court for the Western District of Missouri and held that the patent was invalid and that the John Deere Co. had not infringed upon it.

The other two actions which were consolidated with the Graham case, (No. 37, Calmar, Inc. v. Cook Chemical Co., and No. 43, Colgate-Palmolive Co. v. Cook Chemical Co.) were both declaratory judgment actions filed contemporaneously against Cook Chemical Company. Calmar was a producer of “hold-down” sprayers for bottles of chemicals such as insecticides, and Colgate-Palmolive was a purchaser of these sprayers. Inventor Baxter I. Scoggin, Jr. had assigned his patent for sprayer design to Cook Chemical Co. Calmar and Colgate-Palmolive sought a declaration of invalidity and non-infringement of the patent, and Cook Chemical Co. sought to maintain an action for infringement. The validity of the patent was sustained by the District Court and the Eighth Circuit affirmed.