Derosa v. J.P. Walsh & J.L. Marmo Enterprises, Inc.

NOTE: This order is nonprecedentia1. United States Court of Appeals for the Federal Circuit JOHN L. DEROSA, Plaintiff-Appellee, V. J.P. WALSH & J.L. MARMO ENTERPRISES, INC., Defendant-Appellant. ' 2012-1401 - Appeal from the United States District Court for the Eastern District of Virginia in case no. lO-CV-OZS'?, Judge Claude M. Hilton. ORDER The court considers whether this appeal should be transferred to the United States Court of Appeals for the Fourth Circuit. In order for this court to have jurisdiction over J.P. Wa1sh & J.L. Marmo Enterprises, Inc.’s ("Appellant") appeal, the district court's jurisdiction must have arisen under the patent 1aWs. 28 U.S.C. §§ 1295(a)(1) and 1338. In Holmes Group, Inc. u. Vornado Air Circulcztion Sys- tems, Inc., 535 U.S. 826, 830 (2002), the Supreme Court held: JOHN DEROSA V. J.P. WALSH 2 The well-pleaded-complaint rule has long governed whether a case "arises under” fed- eral law for purposes of § 1331. As "appro- priately adapted to § l338(a),” the well- pleaded-complaint rule provides that whether a case "arises under" patent law "must be determined from what necessarily appears in the plaintiffs statement of his own claim in the bill or declaration...." The plaintiffs well-pleaded complaint must "es- tablis[h] either that federal patent law cre- ates the cause of action or that the plaintiffs right to relief necessarily depends on resolu- tion of a substantial question of federal pat- ent law....” (Citations omitted.) In this case, it appears John L. Derosa’s complaint is devoid of any patent claims and, thus, the district court's jurisdiction was not based on § 1338. The fact that Appel- lant counterclaimed for patent infringement is not suffi- cient to confer jurisdiction upon this court. Id. at 832. We note that the Leahy-Smith America lnvents Act, Public Law 112-29, ("America lnvents Act") does not change this analysis, as the changes to 28 U.S.C. § 1295(a)(1) apply to any civil action commenced on or after September 16, 2011.1 1 Section 19 of the American lnvents Act amends 28 U.S.C. § 1295(a)(l) as follows: (a) The United States Court of Appeals for the Federal Circuit shall have exclusive jurisdiction -- (1) of an appeal from a final decision of a district court of the United States . . . in any civil action arising under, or in any civil action in which a party has as- 3 JOHN DEROSA V. J.P. WALSH Accordingly, IT Is ORDERED THAT: Absent objection received within 21 days of the date of filing of this order, this appeal shall be transferred to the United States Court of Appeals for the Fourth Circuit pursuant to 28 U.S.C. § 1631. FoR THE CoURT JUL 13 mm /S/Jan Horbaly Date J an Horbaly Clerk cc: William E. Hassan, Esq. Thomas P. Pavelko, Esq. s25 “'s'ricfiuz=tnsai\i c\ncurfoa JU|_ 'l 3 2012 JAN HUHBN.Y CLERK serted a compulsory counterclaim aris- ing under, any Act of Congress relating to patents or plant variety protection. Section 19(e) of the America lnvents Act states "[t]he amendments made by this section shall apply to any civil action commenced on or after the date of the enactment of this Act.”