Graham v. John Deere Co.

Graham v. John Deere Co.
Supreme Court of the United States
Argued October 14, 1965 Decided February 21, 1966
Full case name	William T. Graham, et al. v. John Deere Co. of Kansas City, et al., together with No. 37, Calmar, Inc. v. Cook Chemical Co., and No. 43, Colgate-Palmolive Co. v. Cook Chemical Co., also on certiorari to the same court.
Citations	383 U.S. 1 (more) , 86 S.Ct. 684, 15 L.Ed.2d 545, 148 U.S.P.Q. 459
Prior history	336 F.2d 110 (8th cir.) , reversed; 333 F.2d 529 (8th cir., 1964) affirmed
Holding
The nonobviousness requirement set forth in 35 U.S.C. §103 was meant to codify the previous common law requirement that an invention be a significant improvement in the art.
Court membership
Chief Justice Earl Warren Associate Justices Hugo Black · William O. Douglas Tom C. Clark · John M. Harlan II William J. Brennan, Jr. · Potter Stewart Byron White · Abe Fortas
Case opinions
Majority	Clark, joined by Warren, Black, Douglas, Harlan, Brennan, White
Stewart and Fortas took no part in the consideration or decision of the case.
Laws applied
U.S. Const. Art. I, § 8, cl. 8, 35 U.S.C. § 103

Graham v. John Deere Co., 383 U.S. 1 (1966), was a case in which the United States Supreme Court clarified the nonobviousness requirement in United States patent law, set forth in 35 U.S.C. § 103.

The case was actually a set of consolidated appeals of two cases, originating in the same court and dealing with similar issues. The named petitioner, William T. Graham, had sued the John Deere Co. for patent infringement. The invention in question was a combination of old mechanical elements: a device designed to absorb shock from the shanks of chisel plows as they plow through rocky soil and thus to prevent damage to the plow. Graham sought to solve this problem by attaching the plow shanks to spring clamps, to allow them to flex freely underneath the frame of the plow. He applied for a patent on this clamp, and in 1950, obtained U.S. Patent 2,493,811 (referred to by the Court as the '811 patent). Shortly thereafter, he made some improvements to the clamp design by placing the hinge plate beneath the plow shank rather than above it, in order to minimize the outward motion of the shank away from the plate. He applied for a patent on this improvement, which was granted in 1953 as U.S. Patent 2,627,798 (referred to by the court as the '798 patent). While Graham’s patent had been upheld in a previous case before the United States Court of Appeals for the Fifth Circuit, the United States Court of Appeals for the Eighth Circuit reversed the opinion of the United States District Court for the Western District of Missouri and held that the patent was invalid and that the John Deere Co. had not infringed upon it.