Alexis Caswell Angell
How Judge Angell rules, drawn from 8 signed orders. Every observation links to the order it came from.
Judge Angell no longer hears cases. This profile is preserved as a historical record of how they ruled here.
About Judge Angell
Alexis Caswell Angell was a judge of the United States District Court for the Eastern District of Michigan. Appointed by President William H. Taft, Judge Angell received a commission on March 2, 1911. Judge Angell resigned on June 1, 1912.
How Judge Angell decides
Patterns drawn from this judge's own signed orders. Every observation links to the order it came from.
What persuades
Angell treated a corporation's continuous local office, substantial sales, and authority to close transactions as evidence that it was doing business in the state rather than merely soliciting interstate orders.
“The business it did in Michigan was substantial, amounting to a large sum per annum. Its presence in the state by its agent was continuous, and not occasional or casual.”
He required a dissolved corporate plaintiff with no shown collectible assets to protect the defendant against an unrecoverable cost award.
“Under the showing made, it is to my mind reasonable and proper to direct that the plaintiff give security in the sum of $100, with adequate sureties, for all costs which may be awarded against it in this action.”
Procedural preferences
Angell treated litigation costs as creatures of statute and declined to create an allowance where the governing provisions supplied none.
“costs are in the main, if not entirely, statutory allowances”
He conditioned early delivery of salvaged property on joinder, appraisal, and a protective bond so that absent interests would not be prejudiced.
“It is obvious, from what has been said, that in my judgment an appraisement cannot properly be had until the owner of the hull and the owner of the cargo, and their respective underwriters, are brought before the court in some proper mode”
Cautions
Angell would not extend a narrowly construed patent to a device that achieved stability through a materially different mechanism.
“A device which depends on this bearing and this bend to maintain the wire in place, and not alone, if at all, on the frictional engagement of the spirally coiled wire with the edges of the perforations, cannot properly be held a mere evasion of a device which depends solely on such engagement for stability.”
In product-presentation disputes, he required deception of an ordinarily attentive purchaser rather than confusion attributable only to carelessness.
“The rule is settled that ‘equity will not interfere where ordinary attention by the purchaser would enable him to discriminate’ between the goods put out by the parties, and that one is not hound to prevent a purchase by a careless purchaser.”
Signed rulings
A grounded sample of orders signed by this judge, with the verbatim dispositive language.
“The request was denied, and a prolonged argument was had before the court.”
“From these conclusions, it follows that the motion to set aside service of process upon the defendants must be denied.”
Angell enjoined Saginaw from removing the power company's street equipment because the city's revocation resolution was unauthorized and void.
“If. after these parties are brought in, the libelant chooses to proceed in accordance with this opinion, it may do so; otherwise its application for delivery of the rails must be denied.”
Angell dismissed the maritime coal-lien claim because the supplier had relied on the purchaser in possession rather than extending credit to the tugs and had not investigated the purchaser's obligation to pay operating expenses.
“I am compelled, by the foregoing considerations and in the present state of the statutes, to deny the plaintiff’s application.”
“An order for the filing of such security may be entered.”
Angell rejected the trademark and unfair-competition claims because the shared package features were common to the trade and an ordinarily attentive purchaser could distinguish the products.
Angell dismissed the patent suit after concluding that the accused spring-seat device used a materially different mechanism from the narrowly protected invention.
Caseload & timing
From public federal docket records for this judge.
No case-level docket record was returned for Angell's tenure. The profile therefore makes no claim about his complete caseload mix, case duration, administrative dispositions, or motion timing.
A historical record
Judge Angell no longer hears cases. This profile stays available as a record of how they ruled here. If you're preparing for a matter, start from the court's current bench.