Facts of the Case
In 1976, Bonito Boats, Inc. (Bonito), a Florida corporation, developed a design for a fiberglass recreational boat and made a model to produce the finished fiberglass boats for sale. No patent application was ever filed for protection. In 1983, the Florida Legislature enacted a statute making it unlawful to use a direct modeling process to duplicate and sell a vessel or part of a vessel. In 1984, Bonito sued Thunder Craft Boats, Inc. (Thunder Craft), a Tennessee corporation, in the Florida district court for violating the statute. Thunder Craft successfully argued that the Florida statute conflicted with federal patent laws and was therefore invalid under the Supremacy Clause of the Eleventh Amendment. The Florida Court of Appeals and the Florida Supreme Court affirmed the district court’s conclusion that the Florida law interfered with federal patent laws.
Questions
Does a state statute, which prohibits the use of the direct molding process of a vessel that does not have patent protection and the sale of the duplicates, conflict with the federal patent law and therefore make it invalid under the Supremacy Clause of the Eleventh Amendment?
Conclusions
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Yes. Justice Sandra Day O’Connor delivered the unanimous opinion of the Court, which held that, under the Federal Constitution’s Supremacy Clause of the Eleventh Amendment, the federal patent system prevents the Florida statute. The Florida statute offered patent-like protection for ideas deemed unprotected under the federal patent system. This protection restricted the public’s ability to use unpatented designs, which conflicted with the free competition in ideas without patent protection that the federal patent system supported. Therefore, this Florida statute entered into a field of regulation that the patent laws have reserved for Congress, and Congress had declined to exercise.