Incomplete Written Analysis Results in Reversal of Summary Judgment

Warner-Lambert v. Teva Pharmaceuticals (Fed. Cir. 2005).

In a dispute over Warner-Lambert's control over its ACE inhibitor quinapril, the district court granted summary judgment of validity in Warner-Lambert's favor.  Teva appealed, arguing that the patent was not enabled.

On appeal, the CAFC reversed and remanded.  Specifically, the appellate panel questioned the district court's summary judgment opinion that lacked any analysis of the enablement issue:

At the outset, we find the issue of enablement difficult to review because the district court did not address it in its decision granting Warner-Lambert’s summary judgment motion. We have no way of knowing what the district court thought of Teva’s enablement defense or why the court did not address the issue in its decision. In short, we are being asked to review an incomplete record.

Based on the evidence presented by Teva and a lack of written justification for the district court judgment, the CAFC held that Teva should be given another opportunity to present its case.