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Return Mail v. U.S. Postal Service

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Supreme Court of the United States
Return Mail v. U.S. Postal Service
Term: 2018
Important Dates
Argument: February 19, 2019
Decided: June 10, 2019
Outcome
Reversed and remanded
Vote
6-3
Majority
Chief Justice John G. Roberts • Clarence Thomas • Samuel Alito • Sonia Sotomayor • Neil Gorsuch • Brett Kavanaugh
Dissenting
Stephen Breyer • Ruth Bader Ginsburg • Elena Kagan


Return Mail v. U.S. Postal Service is a patent law case argued before the Supreme Court of the United States on February 19, 2019, during the court's 2018-2019 term. The case came on a writ of certiorari to the United States Court of Appeals for the Federal Circuit.[1]

On June 10, 2019, the court reversed the ruling of the United States Court of Appeals for the Federal Circuit and remanded the case. The court held the government "is not a 'person' capable of instituting" review proceedings under the Leahy-Smith America Invents Act.[2] Click here for more information about the opinion.

HIGHLIGHTS
  • The case: Return Mail, Inc. filed a lawsuit against U.S. Postal Service (USPS) alleging that the postal service used its patented mail processing system unlawfully and alleging that it infringed upon the patent. USPS filed a petition with the Patent and Trademark Office’s Patent Trial and Appeal Board (Board) and the Board ruled that the challenged patent claims were unpatentable.
  • The issue: Whether the government is a "person" who may petition to institute review proceedings under the Leahy-Smith America Invents Act (AIA).[3]
  • The outcome: On June 10, 2019, the court reversed the ruling of the United States Court of Appeals for the Federal Circuit and remanded the case. The court held the government "is not a 'person' capable of instituting" review proceedings under the Leahy-Smith America Invents Act.[2]


    • You can review the lower court's opinion here.[4]

    Timeline

    The following timeline details key events in this case:

    • June 10, 2019: U.S. Supreme Court reversed and remanded the ruling of the Federal Circuit
    • February 19, 2019: Oral argument
    • October 26, 2018: U.S. Supreme Court agreed to hear case
    • May 14, 2018: Petition filed with U.S. Supreme Court
    • August 28, 2017: Federal Circuit affirmed the ruling of the U.S. Patent and Trademark Office’s Patent Trial and Appeal Board

    Background

    Return Mail, Inc. patented a system for processing returned mail that is unable to be delivered and tried unsuccessfully to license the patent to the U.S. Postal Service (USPS). Return Mail then filed a lawsuit against USPS alleging the postal service used the processing system unlawfully and infringed upon the patent.[5]

    USPS filed a petition with the Patent and Trademark Office’s Patent Trial and Appeal Board (Board) making the case that the patent was unpatentable. "The Board held that USPS was not statutorily barred from filing the petition for review, and on the merits determined that all of the challenged patent claims were unpatentable under 35 U.S.C. § 101," according to Oyez. The United States Court of Appeals for the Federal Circuit affirmed the ruling of the Board.[5]

    Return Mail appealed to the Supreme Court, and the court agreed to hear the case on October 26, 2018.

    Question presented

    The petitioner presented the following question to the court:[3]

    Question presented:
    • Whether the government is a "person" who may petition to institute review proceedings under the AIA.

    Outcome

    In a 6-3 opinion on June 10, 2019, the court reversed the ruling of the United States Court of Appeals for the Federal Circuit and remanded the case. The court held the government "is not a 'person' capable of instituting" review proceedings under the Leahy-Smith America Invents Act.[2]

    Justice Sonia Sotomayor delivered the opinion of the court. Justice Stephen Breyer filed a dissenting opinion, joined by Justices Ruth Bader Ginsburg and Elena Kagan.[2]

    Opinion

    In her opinion, Justice Sotomayor wrote:[2]

    “ The patent statutes do not define the term 'person.' In the absence of an express statutory definition, the Court applies a 'longstanding interpretive presumption that "person" does not include the sovereign,' and thus excludes a federal agency like the Postal Service. ...


    This presumption reflects 'common usage.' Mine Workers, 330 U. S., at 275. It is also an express directive from Congress: The Dictionary Act has since 1947 provided the definition of "'person'" that courts use '[i]n determining the meaning of any Act of Congress, unless the context indicates otherwise.' 1 U. S. C. §1; see Rowland v. California Men’s Colony, Unit II Men’s Advisory Council, 506 U. S. 194, 199–200 (1993). The Act provides that the word " 'person' . . . include[s] corporations, companies, associations, firms, partnerships, societies, and joint stock companies, as well as individuals." §1. Notably absent from the list of 'person[s]' is the Federal Government. [6]

    		”

    Dissenting opinion

    Justice Breyer filed a dissenting opinion, joined by Justices Ginsburg and Kagan.[2]

    In his dissent, Breyer wrote:[2]

    “ The Court reaches [its] conclusion based on the interpretive presumption that the word 'person' excludes the Government. ... We have long said that this presumption may be overcome when '"[t]he purpose, the subject matter, the context, the legislative history, [or] the executive interpretation . . . indicate an intent"' to include the Government. ... And here these factors indicate that very intent. [6] ”

    Text of the opinion

    Read the full opinion here.

    Audio



    Transcript

    See also

    External links

    Footnotes

    1. ↑ Supreme Court of the United States, "17-1594 Return Mail v. U.S. Postal Service," accessed January 28, 2019
    2. ↑ 2.0 2.1 2.2 2.3 2.4 2.5 2.6 Supreme Court of the United States, Return Mail v. U.S. Postal Service, decided June 10, 2019
    3. ↑ 3.0 3.1 Supreme Court of the United States, "17-1594 Return Mail v. U.S. Postal Service," accessed February 19, 2019
    4. ↑ SCOTUSblog, "Return Mail v. U.S. Postal Service," accessed February 19, 2019
    5. ↑ 5.0 5.1 Oyez, "Return Mail, Inc. v. United States Postal Service," accessed January 29, 2019
    6. ↑ 6.0 6.1 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
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