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Lucky Brand Dungarees v. Marcel Fashion Group

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Supreme Court of the United States
Lucky Brand Dungarees v. Marcel Fashion Group
Term: 2019
Important Dates
Argument: January 13, 2020
Decided: May 14, 2020
Outcome
Reversed and remanded
Vote
9-0
Majority
Sonia Sotomayor • Chief Justice John G. Roberts • Clarence Thomas • Ruth Bader Ginsburg • Stephen Breyer • Samuel Alito • Elena Kagan • Neil Gorsuch • Brett Kavanaugh


Lucky Brand Dungarees v. Marcel Fashion Group is a case argued before the Supreme Court of the United States on January 13, 2020, during the court's October 2019-2020 term. The case came on a writ of certiorari to the United States Court of Appeals for the 2nd Circuit. It concerned trademark infringement and several legal challenges between apparel companies Marcel Fashion Group, Inc. ("Marcel") and Lucky Brand Dungarees, Inc. ("Lucky Brand").

The court reversed the decision of the 2nd Circuit in a unanimous ruling. The court held that Marcel cannot prevent Lucky Brand from raising new defense arguments in the case because the previous litigation (in 2003 and 2005) challenged different actions involving different trademarks occurring at different times.[1] Click here for more information.

HIGHLIGHTS
  • The case: Apparel companies Marcel Fashion Group, Inc. ("Marcel") and Lucky Brand Dungarees, Inc. ("Lucky Brand") filed several lawsuits for trademark infringement. In 2011, Marcel sued Lucky Brand a third time for trademark infringement. The Southern District of New York granted summary judgment to Lucky Brand, ruling a previous lawsuit barred Marcel from suing Lucky Brand. On appeal, the 2nd Circuit Court of Appeals reversed the decision. On remand, Lucky Brand moved to dismiss the suit, which the district court granted. Marcel appealed to the 2nd Circuit, which vacated the Southern District of New York's ruling and remanded the case. Lucky Brand appealed to the U.S. Supreme Court, arguing the 2nd Circuit's decision conflicted with decisions from other circuit courts on similar issues.[2][3]
  • The issue: Whether, when a plaintiff asserts new claims, federal preclusion principles can bar a defendant from raising defenses that were not actually litigated and resolved in any prior case between the parties.[4]
  • The outcome: The court held in a unanimous ruling that Marcel cannot prevent Lucky Brand from raising new defense arguments in the case because the previous litigation (in 2003 and 2005) challenged different actions involving different trademarks occurring at different times. The 2nd Circuit's ruling was reversed and remanded.[1]


    • You can review the lower court's opinion here.

    Timeline

    The following timeline details key events in this case:

    • May 14, 2020: The U.S. Supreme Court reversed the 2nd Circuit's ruling and remanded the case.
    • January 13, 2020: Oral argument
    • June 28, 2019: The U.S. Supreme Court agreed to hear the case.
    • February 15, 2019: Lucky Brand Dungarees, Inc., the petitioner, filed a petition with the U.S. Supreme Court.
    • August 2, 2018: The 2nd Circuit vacated the Southern District of New York's ruling and remanded the case.

    Background

    In 2003, Marcel Fashions Group, Inc. ("Marcel") and Lucky Brand Dungarees, Inc. ("Lucky Brand"), two competing apparel companies, settled a lawsuit in which Marcel accused Lucky Brand of trademark infringement. In the agreement, Lucky Brand agreed to stop using the "Get Lucky" mark and Marcel agreed to release certain future claims from its trademarks.[2]

    Both companies disputed the scope of the agreement. In 2005, the companies sued each other over the use of the "Get Lucky" mark and trademark infringement. Lucky Brand alleged Marcel released any claim on the infringement of trademarks registered prior to the 2003 settlement and moved to dismiss the lawsuit. Marcel argued Lucky Brand committed trademark infringement on a range of Lucky Brand marks that were registered after 2003. The district court denied Lucky Brand's motion. A jury then found that Lucky Brand infringed on the "Get Lucky" mark and the district court prohibited Lucky Brand from using it.[2][3]

    In 2011, Marcel again sued Lucky Brand for trademark infringement. The United States District Court for the Southern District of New York granted summary judgment to Lucky Brand, ruling the 2003 litigation barred Marcel from bringing claims against Lucky Brand. On appeal, the 2nd Circuit Court of Appeals reversed the decision. On remand, Lucky Brand moved to dismiss the suit, arguing the 2003 settlement agreement barred Marcel from suing Lucky Brand. Marcel countered that Lucky Brand could not use this argument because Lucky Brand could have pursued this defense in the 2005 litigation but did not. The district court granted Lucky Brand's motion to dismiss. Marcel appealed to the 2nd Circuit, which vacated the Southern District of New York's ruling and remanded the case.[1][2][3]

    Lucky Brand appealed to the U.S. Supreme Court, arguing the 2nd Circuit's ruling conflicted with rulings in similar cases from other circuits.[3]

    Questions presented

    The petitioner presented the following question to the court:

    Question presented:

    Whether, when a plaintiff asserts new claims, federal preclusion principles can bar a defendant from raising defenses that were not actually litigated and resolved in any prior case between the parties.[4]

    Outcome

    In a unanimous opinion written by Justice Sonia Sotomayor, the court reversed the 2nd U.S. Circuit Court of Appeals' ruling and remanded the case. The court held that Marcel cannot prevent Lucky Brand from raising new defense arguments in the case because the previous litigation (in 2003 and 2005) challenged different actions involving different trademarks occurring at different times.[1]

    Opinion

    In her opinion, Justice Sotomayor wrote:

    “ In the latest lawsuit between the two, Lucky Brand asserted a defense against Marcel that it had not pressed fully in a preceding suit between the parties. This Court is asked to determine whether Lucky Brand’s failure to litigate the defense in the earlier suit barred Lucky Brand from invoking it in the later suit. Because the parties agree that, at a minimum, the preclusion of such a defense in this context requires that the two suits share the same claim to relief—and because we find that the two suits here did not—Lucky Brand was not barred from raising its defense in the later action. ...


    At bottom, Marcel’s 2011 Action challenged different conduct—and raised different claims—from the 2005 Action. Under those circumstances, Marcel cannot preclude Lucky Brand from raising new defenses. The judgment of the Second Circuit is therefore reversed, and the case is remanded for proceedings consistent with this opinion.[5]

    		”
    —Justice Sotomayor[1]

    Text of the opinion

    Read the full opinion here.

    Oral argument

    Audio

    Audio of oral argument:[6]


    Transcript

    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 1.2 1.3 1.4 Supreme Court of the United States, Lucky Brand Dungarees v. Marcel Fashion Group, decided May 14, 2020
    2. ↑ 2.0 2.1 2.2 2.3 United States Court of Appeals for the 2nd Circuit, Marcel Fashions Group, Inc. v. Lucky Brand Dungarees, Inc., decided August 2, 2018
    3. ↑ 3.0 3.1 3.2 3.3 Supreme Court of the United States, Lucky Brand Dungarees v. Marcel Fashion Group: "Petition for a writ of certiorari," accessed July 2, 2019
    4. ↑ 4.0 4.1 Supreme Court of the United States, Lucky Brand Dungarees v. Marcel Fashion Group: "Questions presented," accessed July 2, 2019
    5. ↑ Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    6. ↑ Supreme Court of the United States, "Lucky Brand Dungarees v. Marcel Fashion Group," argued January 13, 2020
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