Legille v. Dann
United States Court of Appeals for the District of Columbia Circuit
544 F.2d 1 (D.C. Cir. 1976)
Legille and others (plaintiffs) properly addressed, stamped, and airmailed four patent applications from Connecticut to the Patent Office in Washington, D.C., a trip that typically took two days by airmail; the Patent Office's dual-employee date-stamping procedure recorded the package as received a week later, causing three applications to be denied for missing their filing deadline. The district court granted Legille summary judgment based on the presumption that properly mailed items are promptly delivered, and the Patent Office appealed.
Whether summary judgment is warranted when a mail recipient offers evidence of the integrity of its mail-handling procedures to rebut the presumption that properly addressed, stamped, and deposited mail arrives within a certain number of days.