American Well Works Co. v. Layne and Bowler Co.

1916

Venue: SCOTUS

Facts: The plaintiff makes a well-regarded pump, and the defendants are said to have slandered and libeled that pump by claiming that they made components of it and that the plaintiffs are infringing on the defendants' patents.

Posture: Suit in state court. Removed to federal court.

Issue: Does this suit arise under federal patent law?

Holding: No. Reversed.

Rule: A suit arises under the law that creates the cause of action.

Reasoning: The claim for damages is based upon language that is said to cause people not to want to be customers, not patents. A suit for damages caused by a threat to sue under patent law is not itself a suit under patent law. What makes the defendants' act a wrong is not a patent-law issue.

Dicta: This is a state law case, and if the state decided to get rid of this cause of action altogether, it wouldn't make any sense to think that the patent laws would allow you to bring it in federal court.