Today, the Federal Circuit decided a patent infringement case and another involving an action against the United States for breach of fiduciary duty relating to the government's distribution of revenue derived from an Indian reservation.
In Richardson v. Stanley Works, Inc., No. 09-1354, the court faced a challenge to the district court's finding of noninfringement relating to a design patent for a multi-function carpentry tool that combines a hammer with another tool. In affirming the decision, the court held that the district court correctly construed the claims at issue and correctly determined that the patent was not infringed.
In Hoopa Valley Tribe v. US., No. 09-5084, the court faced a challenge to the Court of Federal Claims' entry of judgment in favor of the government on the ground that the plaintiff lacked standing to challenge the distribution of trust funds to the Yurok Tribe, from the Settlement Fund that was established under the Hoopa-Yurok Settlement Act.
As stated in the decision: "The Hoopa Valley Tribe waived any claim against the government arising from the Act, received its share of the Settlement Fund, and retained no entitlement to the remainder in the Settlement Fund. As such, at the time DOI distributed the remainder to the Yurok Trine, the Hoopa Valley Tribe was not a beneficiary of, and had no legally protected interest in, the Settlement Fund.
Thus, the court affirmed the decision of the Court of Federal Claims and held that the plaintiff lacked standing because it cannot show an injury in fact.