TC Heartland LLC v. Kraft Foods Group Brands LLC (16-341)

argument 16-341

TC Heartland LLC v. Kraft Foods Group Brands LLC

Supreme Court of the United States 1h 0m 4 speakers 8 chapters transcribed 7 days ago official recording ↗

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What historic choice does the Court face in TC Heartland v. Kraft?

John G. Roberts 0:00

We'll hear argument next in case sixteen three forty one T C Hartland versus craft. Foods. Mr Dabney.

Andrew D. Finch 0:10

Mr Chief Justice, and may it please the court. The court in this case is presented with an historic choice. That choice is between upholding or destroy. Venue protections that Congress provided in twenty eight USC fourteen hundred B And that this court interpreting that statute declared to exist in its four co glass decision. And the correct choice we submit is to adhere. to this Court's existing, long established interpretation of Section fourteen hundred B. and to reject the new uh call for a new revi revisionist interpretation that would render Section fourteen hundred B nugatory in this case and in all but the most unusual cases. I'd like to open first with some undeniable points. In four code glass This Court made two holdings about fourteen hundred B.

Andrew D. Finch 1:14

that control this case. The first is This court interpreted section fourteen hundred B as a standalone. the sole and exclusive provision governing venue in patent cases and is not to be supplemented. with section thirteen ninety one.

Elena Kagan 1:31

How can that be when in Burnett we said that thirteen ninety one governed um aliens, the definition of aliens? So that broad statement we couldn't have met.

Andrew D. Finch 1:44

uh what the court held in brunette was that venue legislation uh had since the beginning of the Republic uh been uh uh uh uh extended only to United States domestic persons and that the then existing thirteen ninety one D of Title twenty eight was not a venue rule at all, but rather was a codification uh of a principle that dated back to seventeen eighty nine that aliens were simply outside the scope of all venue laws.

Elena Kagan 2:09

So what do we do with unincorporated associations

Andrew D. Finch 2:15

Well we do with unincorporated

Elena Kagan 2:16

those are not defined by fourteen hundred.

Andrew D. Finch 2:18

Uh well fourteen hundred B in Fourco was held to apply to all defendants. That was one ground on which this court held in Fourco that fourteen hundred B was standalone precisely because its predecessor had applied to any person, corporation, or partnership. uh and there was never any practical issue interpreting fourteen hundred B as uh in litigation involving uh limited partnerships and even unincorporated nonperson associations because the linchpin of fourteen hundred B and its predecessor was domicile. When you have a venue rule that keys to domicile and specifically distinguishes between a disomiciliary and a non domiciliary, then the problems that the Denver and Rio Grande case addressed and that respondent uh brings up as hypothetical problems uh simply didn't exist.

Andrew D. Finch 3:07

Uh it's noteworthy that in in the respondent's brief they don't cite a single real world example where there was any problem interpreting and applying Section fourteen hundred B ever since the sperry against American Railroad case.

Unknown 3:21

Is there any Other provision, then you provision. in which a co venue for a corporation is only the place of incorporation.

Andrew D. Finch 3:33

Or venue for a corporation is only the place of incorporation. I I cannot stand here, Your Honor, uh and identify uh uh it could very well be that there is one, and that's a very good reason why uh when Congress amended thirteen ninety one in twenty eleven they put that broad exception language in.

Unknown 3:52

Well don't you suppose I mean Even for diversity. purposes a cooperation is it is diverse based on not simply its place of incorporation but its principal place of business. Principal place of business counts. Doesn't count under 1400.

Andrew D. Finch 4:13

Well, since 1948, that has been the general rule that 1391 C has provided. 1391 C has said for sixty odd years that a corporation, regardless of its domicile, will be deemed to be resident. in this district, that district, that district, and that has been a feature of general venue law uh since 1948. The whole point here is that it that that rule was urged upon this court in the Foucault Glass case. The court considered statutory language that was not materially different in this respect from current 1391 and held that Fourteen hundred B when it says the judicial district where the defendant resides, that means domicile.