CIVIL PROCEDURE, CIVIL RIGHTS, CONSTITUTIONAL LAW, GOVERNMENT LAW, LABOR & EMPLOYMENT LAW
Engquist v. Oregon Dep’t of Agric., No. 07-474
The “class-of-one” theory of equal protection does not apply in the context of public employment. Thus, a public employee cannot state a claim under the Equal Protection Clause by alleging that she was arbitrarily treated differently from other similarly situated employees, with no assertion that the different treatment was based on the employee’s membership in any particular class.
CIVIL PROCEDURE, CRIMINAL LAW & PROCEDURE, GOVERNMENT LAW, INJURY AND TORT LAW, PROPERTY LAW & REAL ESTATE, TAX LAW
Bridge v. Phoenix Bond & Indem. Co., No. 07-210
A plaintiff asserting a Racketeer Influenced and Corrupt Organizations Act (RICO) claim predicated on mail fraud need not show, either as an element of its claim or as a prerequisite to establishing proximate causation, that it relied on the defendant’s alleged misrepresentations.
GOVERNMENT CONTRACTS, GOVERNMENT LAW, INJURY AND TORT LAW, MILITARY LAW
Allison Engine Co., Inc. v. US ex rel. Sanders, No. 07-214
In the context of the False Claims Act, it is insufficient for a plaintiff asserting a 31 U.S.C. section 3729(a)(2) claim to show merely that “[t]he false statement’s use … result[ed] in obtaining or getting payment or approval of the claim,” or that “government money was used to pay the false or fraudulent claim.” Instead, a plaintiff asserting such a claim must prove that the defendant intended that the false record or statement be material to the government’s decision to pay or approve the false claim. Similarly, a plaintiff asserting a claim under section 3729(a)(3) must show that the conspirators agreed to make use of the false record or statement to achieve this end.
INTELLECTUAL PROPERTY, PATENT
Quanta Computer, Inc. v. LG Elecs., Inc., No. 06-937
In a patent case involving computer technology patents, a circuit court’s ruling in favor of plaintiff-LG Electronics and against defendants-computer manufacturers is reversed where: 1) contrary to the holding below, the exhaustion doctrine applies to method patents; and 2) because a license agreement authorized the sale of components that substantially embodied the patents in suit, the sale exhausted the patents.