Alexis Caswell Angell

United States District Court for the Eastern District of Michigan district Retired 1912 · served 1911–1912 Appointed by William Howard Taft (Republican) 8 signed orders read

Judge Angell no longer hears cases. This profile is preserved as a historical record of how they ruled.

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.

Michigan Aluminum Foundry Co. v. Aluminum Castings Co.
Motion for jury determination (defendant) Denied

“The request was denied, and a prolonged argument was had before the court.”

Motion to set aside service (defendant) Denied

“From these conclusions, it follows that the motion to set aside service of process upon the defendants must be denied.”

Saginaw Power Co. v. City of Saginaw
Permanent injunction (power company) Granted

“The complainant is entitled to a permanent injunction against the action of the defendants under said resolution looking to such removal of poles, wires, conduits, and apparatus.”

Sea Ins. v. About 500 Tons of Steel Rails
Application for delivery of salvaged property (cargo insurer) Moot / procedural

“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.”

The Strohn
Maritime supply lien claim (coal supplier) Denied

“For the reasons stated, and without passing upon other matters discussed by counsel, the libel should be dismissed.”

Michigan Aluminum Foundry Co. v. Aluminum Co. of America
Motion for costs (plaintiff) Denied

“I am compelled, by the foregoing considerations and in the present state of the statutes, to deny the plaintiff’s application.”

Handy Varnish Co. v. Midland Linseed Oil Co.
Motion for security for costs (defendant) Granted

“An order for the filing of such security may be entered.”

American Tobacco Co. v. Globe Tobacco Co.
Trademark and unfair competition claim (complainant) Denied

“Decree must be entered for defendant.”

Murray v. Detroit Wire Spring Co.
Patent infringement claim (complainant) Denied

“Under the construction heretofore given the Murray patent in the D’Arcy Case, and the rule applicable to alleged infringements of specific patents, I feel compelled to hold that defendant’s device is not an infringement of the Murray patent, and to dismiss the bill.”

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. If you're preparing for a matter, start from the court's current bench.