Jury Instructions and Objective Indicia of Nonobviousness: Federal Circuit Grants New Trial in Inline Plastics v. Lacerta

Jury Instructions and Objective Indicia of Nonobviousness: Federal Circuit Grants New Trial in Inline Plastics v. Lacerta

In a recent decision, the Federal Circuit vacated a judgment of invalidity and remanded for a new trial, holding that the district court’s jury instruction on objective indicia of nonobviousness constituted prejudicial legal error. The case, Inline Plastics Corp. v. Lacerta Group, LLC, No. 2022-1954 (Fed. Cir. Mar. 27, 2024), involved patents relating to tamper-resistant and tamper-evident food containers.

Role of Jury Instructions and Objective Indicia

In American civil litigation, jury instructions are the set of legal rules and guidelines provided to the jury by the trial judge before the jury begins deliberations. These instructions explain the relevant law, legal standards, and how the jury should apply the law to the facts of the case when reaching a verdict. The judge’s role is to ensure the jury instructions accurately reflect the applicable law — while still being delivered in a digestible form that does not unduly confuse the jury or direct the jury’s deliberation.  Attorneys from each side will typically propose specific instructions and object to those they believe are incorrect or incomplete.

At the close of trial, jury instructions are typically given orally by the judge and can also be provided to the jury in writing for reference during deliberations.

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