standard of review

Highmark, Inc. v. Allcare Health Management Systems, Inc.

Issues: 

Is a district court’s finding that a patent suit is objectively baseless entitled to deference?

Respondent Allcare Health Management Systems, Inc., owns U.S. Patent No. 5,301,105, which covers a method of data entry and management used in the context of medical treatment. In 2002, Allcare notified Petitioner Highmark, Inc., a medical insurance provider, that Highmark was infringing on Allcare’s patent. Highmark sought a declaratory judgment of noninfringement; Allcare counterclaimed for infringement. After the district court granted summary judgment in Highmark’s favor, Highmark moved for an award under 35 U.S.C. § 285, which grants attorneys’ fees for “exceptional cases.” Though the district court granted the award for two of Allcare’s claims, the Federal Circuit Court of Appeals reviewed the claims de novo and reversed one of them. The Supreme Court granted certiorari to determine the scope of deference given to district courts to find “exceptional cases.” The ruling in this case, in tandem with another case before the Court, Octane Fitness, LLC v. Icon Health & Fitness, Inc., will impact how long and how readily litigants may pursue future patent cases.

Questions as Framed for the Court by the Parties: 

Whether a district court's exceptional-case finding under 35 U.S.C. § 285, based on its judgment that a suit is objectively baseless, is entitled to deference.

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Facts

Respondent Allcare Health Management Systems, Inc. (“Allcare”) owns U.S. Patent No. 5,301,105 (“the ’105 patent”), which covers a health management system that facilitates interactions among physicians, patients, employers, banks, and insurance companies. See Highmark, Inc. v. Allcare Health Mgmt.

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United States v. Davila

On February 8, 2010, a magistrate judge held a hearing with the defendant, Anthony Davila, and his attorney. At the hearing, the judge encouraged Davila to plead guilty, and on May 11, 2010, Davila pled guilty to the charges. On appeal, Davila successfully argued that the judge’s encouragement constituted a violation of Federal Rules of Criminal Procedure (“FRCP”) 11(c)(1), which generally prohibits the judge from participating in plea-bargaining. The Supreme Court granted certiorari to determine whether any judicial participation in plea-bargaining, as opposed to “prejudicial” participation, mandates automatic reversal of a conviction. The United States argues that FRCP 11(h) requires the appellate court to review Rule 11 errors under the harmless error standard, while Davila counters that an 11(c)(1) error requires automatic reversal. Furthermore, the United States sees many 11(c)(1) violations as technical and harmless, while Davila views such violations as universally prejudicial, making the government’s role effectively redundant. Both Davila and the United States argue that a ruling for the other party will undermine the finality of guilty convictions secured by plea bargains.

Questions as Framed for the Court by the Parties: 

Whether the court of appeals erred in holding that any degree of judicial participation in plea negotiations, in violation of Federal Rule of Criminal Procedure 11(c)(1), automatically requires vacatur of a defendant's guilty plea, irrespective of whether the error prejudiced the defendant.

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Issue

Does a judge’s participation in plea negotiations automatically overturn the defendant’s guilty plea, or does it only overturn the plea if the judge’s participation actually harmed the defendant?

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