Unitherm Food Systems, Inc. v. Swift-eckrich, Inc., Dba Conagra Refrigerated Foods (546 U.S. 394)
U.S. Supreme Court · decided January 23, 2006 · Supreme Court Database (Spaeth)
- Citation
- 546 U.S. 394 · 126 S. Ct. 980
- Decided
- January 23, 2006
- Term
- October Term 2005
- Vote
- 7–2
- Majority author
- Justice Thomas
- Issue area
- Judicial Power
- Disposition
- Reversed
- Outcome
- Petitioning party won
- Ideological direction
- Conservative
Opinion excerpt
Justice Thomas delivered the opinion of the Court. Ordinarily, a party in a civil jury trial that believes the evidence is legally insufficient to support an adverse jury verdict will seek a judgment as a matter of law by filing a motion pursuant to Federal Rule of Civil Procedure 50(a) before submission of the case to the jury, and then (if the Rule 50(a) motion is not granted and the jury subsequently decides against that party) a motion pursuant to Rule 50(b). In this case, however, the respondent filed a Rule 50(a) motion before the verdict, but did not file a Rule 50(b) motion after the verdict. Nor did respondent request a new trial under Rule 59. The Court of Appeals nevertheless proceeded to review the sufficiency of the evidence and, upon a finding that the evidence was insufficient, remanded the case for a new trial. Because our cases addressing the requirements of Rule 50 compel a contrary result, we reverse. I The genesis of the underlying litigation in this case was ConAgra’s attempt to enforce its patent for “A Method for Browning Precooked Whole Muscle Meat Products,” U. S. Patent No. 5,952,027 (’027 patent). In early 2000, ConAgra issued a general warning to companies who sold equipment and processes for browning precooked meats explaining that it intended to “ ‘aggressively protect all of [its] rights under [the ’027] patent.’” 375 F. 3d 1341, 1344 (CA Fed.…
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