Highmark Inc. v. Allcare Health MGMT. SYS. (572 U.S. 559)

U.S. Supreme Court · decided April 29, 2014 · Supreme Court Database (Spaeth)

Citation
572 U.S. 559 · 134 S. Ct. 1744
Decided
April 29, 2014
Term
October Term 2013
Vote
9–0
Majority author
Justice Sotomayor
Issue area
Attorneys
Disposition
Vacated and remanded
Outcome
Petitioning party won
Ideological direction
Liberal

Opinion excerpt

Justice SOTOMAYOR delivered the opinion of the Court. Section 285 of the Patent Act provides: "The court in exceptional cases may award reasonable attorney fees to the prevailing party." 35 U.S.C. § 285. In Brooks Furniture Mfg., Inc. v. Dutailier Int'l, Inc., 393 F.3d 1378 (2005), the United States Court of Appeals for the Federal Circuit interpreted § 285 as authorizing fee awards only in two circumstances. It held that "[a] case may be deemed exceptional" under § 285"when there has been some material inappropriate conduct," or when it is both "brought in subjective bad faith" and "objectively baseless." Id., at 1381. We granted certiorari to determine whether an appellate court should accord deference to a district court's determination that litigation is " objectively baseless." On the basis of our opinion in Octane Fitness, LLC v. Icon Health & Fitness, Inc., ---- U.S. ----, 134 S.Ct. 1749, 188 L.Ed.2d 816, 2014 WL 1672251 (2014) argued together with this case and also issued today, we hold that an appellate court should review all aspects of a district court's § 285 determination for abuse of discretion. I Allcare Health Management System, Inc., owns U.S. Patent No. 5,301,105 (′105 patent), which covers "utilization review" in " 'managed health care systems.' " 687 F.3d 1300, 1306 (C.A.Fed.2012). Highmark Inc., a health insurance company, sued Allcare seeking a…

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