Morris v. Scenera Research, LLC

2012 NCBC 27
Procedural entryThis page is a short order in Morris v. Scenera Research, LLC. Read the opinion of the Court — 2011 NCBC 33
North Carolina Business Court·Decided May 14, 2012·No. 09-CVS-19678·Published

Opinion

Morris v. Scenera Research, LLC, 2012 NCBC 27.

STATE OF NORTH CAROLINA IN THE GENERAL COURT OF JUSTICE SUPERIOR COURT DIVISION COUNTY OF WAKE 09 CVS 19678

ROBERT PAUL MORRIS, ) ) Plaintiff, ) ) v. ) ) JUDGMENT SCENERA RESEARCH, LLC, and ) RYAN C. FRY, ) ) Defendants. ) )

{1} This matter is before the court for Entry of Judgment following a jury trial. The court narrowed the issues for trial by its grant of partial summary judgment by order dated January 4, 2012. The case was called for trial on January 30, 2012. At the close of the evidence, the court directed a verdict for Defendant Scenera Research, LLC (“Scenera”) on the issue of patent ownership because Plaintiff had not presented evidence necessary to support any claim to ownership under the guidelines set by the court’s summary judgment order. On February 15, 2012, the jury returned a verdict in favor of Plaintiff Robert Paul Morris (“Morris”) on all remaining claims. Morris seeks Judgment on the jury verdict as well as supplemental relief on his statutory claims. Scenera seeks judgment on the patent ownership claim consistent with the court’s summary judgment order and its grant of a directed verdict.

I. FACTUAL BACKGROUND {2} A broad overview of the claims is instructive in understanding the jury’s verdict on the ten Issues submitted. {3} The evidence was undisputed that Morris was employed by Scenera and that his employment ended on July 10, 2009. The reasons for and who initiated the end of his employment, however, were very much disputed. The evidence was also undisputed that both Scenera and Defendant Ryan C. Fry (“Fry”) were Morris’s employers under the North Carolina Wage and Hour Act, N.C. Gen. Stat. §§ 95-25.1 et seq. (“Wage Act”) and the North Carolina Retaliatory Employment Discrimination Act, N.C. Gen. Stat. §§ 95-240 et seq. (“REDA”). {4} The evidence was also undisputed that Morris had, prior to his employment with Scenera, done work as an independent contractor to Scenera pursuant to a written agreement while he was employed by a related company, but that he later become employed by Scenera and that the initial terms agreed to as a part of his employment with Scenera were not reduced to writing. The Parties agreed that there was a verbal agreement, and that Morris would in addition to a base salary receive bonus compensation for inventions Morris made during his employment. The bonus compensation included $5,000 to become due at the time of assignment of the invention and execution of a patent application, and an additional $5,000 when a patent issued from such an application. {5} The Parties disagreed whether Morris was entitled to a patent issuance bonus if he was not employed at the time a patent issued. The Parties also disagreed whether Morris was “hired to invent” and the correlated issue of whether he ever had any ownership in any invention he made during the term of his employment. Morris claimed that he had not been “hired to invent” and that inventions were not a part of his regular employment duties, such that he controlled the option of whether to offer to assign any invention. Consequently, he contended that he was not obligated to assign and further had the right to rescind any prior assignment for failure of consideration upon Defendants’ refusal to pay disputed patent bonuses. Defendants on the other hand contended that Morris was “hired to invent,” and ownership of the inventions is independent of the disputed wage claims, so that ownership of any such invention immediately vested in Scenera. As a result, Defendants contended that ownership of an invention vested in Scenera without the need for any express assignment, and that Morris is obligated as a matter of law to assign any such invention not already assigned, with no right to rescind any prior assignment. The Parties also disputed whether Morris was, in addition to the assignment, required to support the patent through the application process in order to “earn” any patent issuance bonus. The undisputed evidence was that on the date Morris’s employment ended on July 10, 2009, Scenera had 150 pending patent applications on inventions for which Morris was the inventor. Inventions Morris made during his employment are identified by Exhibit A to his Amended Complaint, which Exhibit is incorporated by reference. Morris, by the time of trial, had assigned executed written agreements on all but a few of these inventions. {6} While the Parties disputed whether any bonuses were due after January 1, 2008, they agreed that any such bonus which is owed qualifies as “wages” under the Wage Act. Defendants denied both that any such wages were owed and the amount which Morris claims even if some bonus compensation is due. The disputes included whether bonuses had been cancelled, whether Morris was eligible for bonuses without being employed at the time the bonus was payable, and whether Morris had “earned” bonuses claim within the meaning of the Wage Act. As an initial matter, the Parties disagreed whether patent bonuses were to continue at all after January 1, 2008. The evidence for both Parties indicated that Morris and Scenera reached agreement on some changes to be implemented as of January 1, 2008, in consideration of Defendants potentially implementing a company-wide incentive compensation plan. Morris maintained that he agreed to suspend, but not cancel, patent application bonuses during 2008 to assist with Scenera’s cash flow, but that payment of patent issuance bonuses was never suspended. Morris contended that assignment bonuses continued to accrue during 2008 and became payable in 2009 and that he never agreed to any alternative incentive compensation plan for himself that would substitute for his existing bonus plan. Defendants contended that Morris had agreed to cancel the patent bonus system entirely, and that Defendants later did implement a company-wide incentive plan more aligned with the company’s profitability, but that Morris demanded greater individual considerations to which he was not due. {7} Morris contended that he is entitled to recover $210,000 for application and issuance bonuses which had accrued as of the date Morris’s employment ended in July 2009. Of that sum, $145,000 had accrued prior to January 1, 2008, and in light of the voluntary payment suspension for 2008, became payable on January 15, 2009. An additional $65,000 accrued after January 1, 2008, and was payable no later than July 15, 2009, the first fifteenth of the month following the end of a calendar quarter. The evidence demonstrated that Morris received $20,000 in 2008 beyond his normal base compensation. Morris contends this compensation was for patent bonuses; Defendants contend it was not, because patent bonuses had been eliminated. Morris believed that Defendants should receive a credit for $20,000 in patent bonuses paid, but that if the $20,000 payment was not for patent bonuses, he was then entitled to accrued unpaid bonus compensation of $230,000 rather than the $210,000 on which he based his claim. {8} The evidence was clear that negotiations over disputed bonuses were undertaken in 2009 when Scenera requested that Morris execute a written employment agreement, and that Morris was the only regular Scenera employee who did not have a written agreement. The evidence also established that throughout these negotiations, Morris consistently made clear his belief that he was entitled to bonuses that had continued to accrue after January 1, 2008. However, it was not until late in the negotiations for an employment agreement that Morris also demanded that he be paid future patent issuance bonuses irrespective of whether he remained employed.

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Morris v. Scenera Research, LLC, 2012 NCBC 27 (N.C. Super. Ct. 2012).

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