Joyce v. General Motors Corp.
49 Ohio St.3d 93, 551 N.E.2d 172, 1990 Ohio LEXIS 86 (1990)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
An idea is not considered legally protected property and therefore cannot be the subject of a conversion claim unless it is expressed in a legally protected manner, such as through a patent, copyright, trademark, or a contractual or fiduciary relationship.
Facts:
- An employee of General Motors ('GM') submitted an idea to the company's formal 'Suggestion Plan,' which offered monetary awards for adopted suggestions.
- The GM Suggestion Committee initially recommended that the employee receive an award payment voucher for his idea.
- Subsequently, a manager named Tackett allegedly directed the committee to cancel the employee's award.
- Tackett then allegedly directed that an award of $12,800 be paid to another employee, Halsey, for the same or a similar idea.
- Following this direction, GM paid the award to Halsey instead of the employee who originally submitted the idea.
Procedural Posture:
- An employee (plaintiff) sued his coworkers, Halsey and Tackett, and his employer, General Motors ('GM'), in an Ohio trial court.
- GM was dismissed as a defendant prior to the trial.
- The trial court overruled the remaining defendants' pre-trial motion to dismiss for failure to state a claim.
- The case proceeded to a jury trial, and at the close of the plaintiff’s evidence, the defendants moved for a directed verdict.
- The trial court granted the defendants' motion for a directed verdict.
- The plaintiff (appellant) appealed to the Ohio Court of Appeals.
- The Court of Appeals reversed the trial court's judgment.
- The defendants (appellants) appealed that reversal to the Supreme Court of Ohio.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does an employee have a viable claim for conversion against coworkers for the alleged appropriation of an idea submitted to their employer's employee suggestion plan, where the idea was not patented, copyrighted, or otherwise protected by a specific contract?
Opinions:
Majority - Moyer, C.J.
No, an employee does not have a viable claim for conversion. An idea, in and of itself, does not rise to the level of legally protected property. For an idea to be protected, it must be expressed in a recognized legal form such as a patent, trademark, copyright, or be imparted pursuant to a fiduciary or contractual relationship. In this case, the employee's ideas were not expressed in any legally protected manner. By freely divulging them through the suggestion plan without a specific contract for confidentiality or ownership, he effectively made a public disclosure, which deprives him of any property rights in them. Since the idea is not property, it is not capable of being converted.
Dissenting - Holmes, J.
Yes, a claim should be permitted, but not for conversion. The majority improperly focuses on property and patent law when the correct legal framework is contract law. An employer's suggestion plan constitutes a unilateral contract offer, which an employee accepts by submitting a suggestion. While the plaintiff may not have a claim for breach of contract against the employer, he has presented sufficient evidence to state a claim for tortious interference with contractual relations against his coworkers, Halsey and Tackett. The dissent argues that the coworkers conspired to interfere with the plaintiff's contractual relationship with GM to deny him the award, and the case should be remanded to the trial court to consider this theory.
Analysis:
This decision reinforces the common law principle that abstract ideas are not property, thereby limiting the tort of conversion to tangible property or well-defined intangible property interests. The ruling places the burden on creators to secure formal legal protection (like patents or copyrights) or establish clear contractual agreements before disclosing their ideas. The dissent highlights a significant alternative legal theory, suggesting that the context of an employer's suggestion plan can create contractual rights that, while not making the idea itself 'property,' are still legally protectable against tortious interference by third parties.
