Brown v. Gardner Case Brief

Facts of the Case

“Claimant Fred P. Gardne was a veteran of the Korean conflict, and he received medical treatment at a Department of Veterans Affairs (VA) facility for a herniated disc unrelated to his prior military service. Subsequently, he developed pain and weakness in his left calf, ankle, and foot, which he alleged was the result of the surgery. He then claimed disability benefits under 38 U.S.C.S. § 1151. The VA and the Board of Veterans’ Appeals denied the claim for benefits on grounds that § 1151, as interpreted by its regulation under 38 C.F.R. § 3.358(c)(3) (1993), only covered an injury if it proximately resulted from fault on the part of the VA or from the occurrence during treatment or rehabilitation of an “accident.” The Court of Veterans’ Appeals reversed the judgment, and the lower court affirmed. Petitioner Secretary of Veterans Affairs sought review.”

Question

Can one patent a machine that transforms materials physically under the control of a programmed computer?

CONCLUSION

No. In a unanimous decision authored by Justice David Souter, the Court affirmed the lower court’s decision and ruled for Gardner. The Court held that Section 1151 contains no language requiring proof of fault, and it rejected the Government’s claims that the requirement was implicit in the language of the statute. The Court acknowledged the 60-year longevity of the regulation and the post-1934 legislative silence on the issue, but neither concern could overcome the plain language of Section 1151.

Case Information

Citation: 513 US 115 (1994)
Argued: Oct 31, 1994
Decided: Dec 12, 1994
Case Brief: 1994