Jerra Bowden v. DB Schenker
693 F. App'x 157
| 3rd Cir. | 2017Background
- Bowden was hired in 2013 as an at‑will Line Lead Supervisor by DB Schenker to manage Repair and Reclaim employees and improve workflows.
- She proposed an assembly‑line ("Taylorism") approach: assign one task per worker rather than one worker per product.
- Schenker tested and later implemented similar procedures in other divisions; Bowden sued claiming misappropriation of ideas, unjust enrichment, and quantum meruit.
- The District Court dismissed all claims without leave to amend; Bowden appealed to the Third Circuit.
- The Third Circuit affirmed, finding the assembly‑line concept is not novel or concrete and that Bowden’s claims failed as a matter of law.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Misappropriation of ideas | Bowden: she originated a novel, concrete assembly‑line method that Schenker adopted. | Schenker: assembly line is not novel; no protectable property; employer reviewed/tested idea and paid Bowden as employee. | Court: dismissed — idea not novel/concrete; no substantial investment, no improper appropriation, public policy disfavors liability. |
| Unjust enrichment | Bowden: Schenker benefited from her idea and should pay. | Schenker: Bowden was salaried and duties encompassed proposing workplace improvements. | Court: dismissed — benefits arose from compensated employment; no inequitable retention. |
| Quantum meruit | Bowden: she provided valuable services/ideas for which she was not compensated. | Schenker: Bowden was compensated; benefit was not wrongfully secured. | Court: dismissed — no unconscionable retention or wrongful securing of benefit. |
| Leave to amend | Bowden: District Court should have allowed amendment. | Schenker: amendment would be futile. | Court: affirmed denial — further amendment would be futile. |
Key Cases Cited
- Blackmon v. Iverson, 324 F. Supp. 2d 602 (E.D. Pa.) (idea protection requires novelty and concreteness)
- Sorbee Int'l Ltd. v. Chubb Custom Ins. Co., 735 A.2d 712 (Pa. Super. Ct.) (elements for misappropriation of ideas)
- McGoldrick v. TruePosition, Inc., 623 F. Supp. 2d 619 (E.D. Pa.) (employee compensation bars unjust enrichment/quantum meruit for job duties)
- Frasier v. Nationwide Mut. Ins. Co., 352 F.3d 107 (3d Cir.) (standards for denying leave to amend)
- Evancho v. Fisher, 423 F.3d 347 (3d Cir.) (appellate review is plenary)
- Fowler v. UPMC Shadyside, 578 F.3d 203 (3d Cir.) (plausibility standard for pleadings)
- Ashcroft v. Iqbal, 556 U.S. 662 (Supreme Court) (pleading standard requiring plausible claim)