Wednesday, November 13, 2013

Bonito Boats, Inc. v. Thunder Craft Boats, Inc. case brief

Bonito Boats, Inc. v. Thunder Craft Boats, Inc. case brief summary
489 U.S. 141 (1989)

Petitioner sought review of the judgment of the Florida Supreme Court holding in favor of respondent in petitioner's action against respondent for unlawful duplication of petitioner's molding process in violation of Fla. Stat. § 559.94 (1987).

Petitioner developed and marketed a fiberglass boat hull. No patent application was filed to protect the utilitarian or design aspects of the hull. The hull was successful and an interstate market developed for the hull's trade. Six years after the hull had been made publicly available, Fla. Stat. § 559.94 (1987) was enacted, which made it unlawful for anyone to duplicate for the purpose of sale the process used by another hull manufacturer without written permission from that person. Petitioner sued respondent alleging that respondent violated the statute by using the same molding process petitioner used to manufacture respondent's hull. In a divided opinion, the state supreme court concluded that the statute impermissibly interfered with federal patent law and dismissed petitioner's complaint. Petitioner appealed.


  • The court held that by offering patent-like protection for ideas deemed unprotected under the federal scheme, the statute conflicted with the federal policy favoring free competition in ideas which did not merit patent protection. 
  • As a result, the statute was preempted by the Eleventh Amendment, and the judgment in favor of respondent was affirmed.

The judgment in favor of respondent was affirmed because the statute under which petitioner sued was federally preempted.

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