SCA Hygiene Products Aktiebolag v. First Quality Baby Products, LLC

On March 21, 2017, the U.S. Supreme Court issued its decision in SCA Hygiene Products Aktiebolag v. First Quality Baby Products, LLC. SCA sued First Quality for infringing patents related to adult incontinence products. The district court granted summary judgment for First Quality, holding that the equitable defense of laches barred SCA’s claim for damages due to unreasonable delay in filing suit. The Federal Circuit affirmed based on its precedent allowing laches against legal claims. The Supreme Court reversed, ruling 7-1 that laches cannot defeat a claim for damages incurred within the Patent Act’s six-year limitations period under 35 U.S.C. §286. Following its reasoning in Petrella v. Metro-Goldwyn-Mayer, the Court held that a statutory limitations period displaces the judge-made doctrine of laches, and remanded the case for further proceedings.

The Supreme Court reversed and remanded in a 7-1 decision. Justice Samuel A. Alito, Jr. delivered the opinion of the Court, holding that laches cannot be invoked against a claim for patent damages incurred within the limitations period because Congress legislated a fixed time bar. Justice Stephen Breyer filed a dissenting opinion.

Whether the equitable defense of laches can bar a claim for patent infringement damages brought within the six-year statutory limitations period established by 35 U.S.C. §286.

The ruling resolved a circuit split and overturned long-standing Federal Circuit precedent, significantly strengthening patent holders' ability to recover damages for infringement occurring within the six-year window even after an unreasonable delay in filing suit. By eliminating laches as a complete bar to legal remedies within the statutory period, the decision harmonized patent law with the copyright law holding in Petrella, altered litigation strategy, and clarified the supremacy of statutory limitation periods over equitable defenses.