This case concerned a Virginia corporation that paid undistributed profits tax for 1937 under the Federal Revenue Act of 1936 and later sought a refund through its receivers, arguing it qualified for a credit as a deficit corporation prohibited by state law from paying dividends. The facts were stipulated, showing net earnings that year but a large accumulated deficit impairing capital. The District Court granted the refund by interpreting Virginia Code Section 3840 to bar dividends from net earnings absent excess assets over capital, but the Fourth Circuit reversed, concluding the statute's disjunctive language permits dividends from net earnings independently of capital status and thus no prohibition or credit applied.
The case involved a Virginia dance hall company suing two military officers for issuing an order declaring its premises off-limits to enlisted personnel, citing unsanitary and immoral conditions, which led to loss of business. The district court granted a preliminary injunction, finding the action deprived the company of property without due process. The appeals court reversed, concluding that the suit was effectively against the United States because the officers acted under valid authority from the Secretaries of War and Navy, requiring those officials to be named as defendants, and that the military's discretionary control over personnel did not constitute a taking or trespass.
This case involved a civil action for damages alleging infringement of three patents (Rahm, Scott, and Webb) related to mechanisms for unscrewing and ejecting threaded molded caps or vials from molding machines. The District Court found no infringement by the defendant's Stokes machine and dismissed the complaint. On appeal, the Fourth Circuit affirmed, holding that the patents were not pioneer inventions and thus required narrow interpretation, with substantial differences between the patented devices and Stokes—such as Rahm's single-step gravity-based removal without mold plate movement versus Stokes's two-step loosening and lateral ejection process, and Scott/Webb's use of separate external frictional devices versus Stokes's integration with mold plates. The court emphasized that the claims must be read in light of the specifications and prior art, and that the patents lacked commercial success.
This case involves a copyright infringement claim by Deward & Rich against Bristol Savings & Loan Corporation for continuing to use copyrighted advertisements after the expiration of a licensing contract. The defendant moved to dismiss, arguing among other things that providing mats without copyright notices constituted an abandonment of the copyright. The court overruled the motion, holding that the advertisements were validly copyrighted and that the defendant, as a contracting party with actual notice, could not rely on the absence of notices on the printed ads to claim abandonment. The reasoning emphasized that copyright notice requirements protect innocent third parties, not parties who had contracted for the use and continued it unauthorizedly.
This case involved a plaintiff who obtained a judgment in Virginia state court for injuries from an automobile accident and then sought to enforce it through a garnishment proceeding against the defendants' insurer, Maryland Casualty Company, under Virginia law. The insurer removed the garnishment to federal district court, prompting the plaintiff's motion to remand it back to state court. The court granted the motion to remand, holding that the garnishment proceeding was an ancillary method of enforcing the existing judgment rather than an independent suit involving new controversies. The reasoning centered on the nature of Virginia's garnishment statute, which the court found to be a supplementary proceeding tied to the original case, consistent with precedents distinguishing ancillary actions from removable independent ones, and emphasizing remand when federal jurisdiction is doubtful.
