Russell v. Place
Supreme Court
94 U.S. (4 Otto) 606 (1876)
Nathan Russell (plaintiff) obtained and later reissued a patent covering two separate leather-treatment processes, then sued Isaac Place and others (Place) (defendants) for using, manufacturing, and selling the patented invention without a license, seeking damages and an injunction. Place admitted using the process but argued it had been publicly used for over two years before Russell applied for the patent and that the reissued patent covered a different invention than the original; judgment was entered for Russell in that first suit, though the record didn't specify which of the two patented processes Place had infringed. Russell then brought a second infringement suit, and Place again tried to raise the same invalidity defenses, prompting Russell to argue the first judgment collaterally estopped Place from raising them again; the lower court ruled for Place, and Russell appealed.
Whether collateral estoppel will always prohibit a party to a lawsuit from raising any issue that was or could have been raised in a previous action between the same parties.