## Facts

- Hisel contacted Chrysler stating he had an idea to improve the appearance of new cars but initially did not disclose it.
- Chrysler responded with a written “new ideas” policy requiring a signed submission form before Chrysler would consider any suggestion.
- The submission form stated that Chrysler assumed no obligation or liability connected to the submission or any use of the suggestion, except liability arising under valid patents.
- Hisel disclosed an idea involving a framed or boxed license-plate mount with a transparent cover and later signed and returned Chrysler’s submission form after Chrysler requested it.
- Chrysler advised Hisel that the idea was not novel and had long been known and used in the automotive industry.
- Hisel sued Chrysler and related corporate entities, alleging confidential disclosure and wrongful appropriation that deprived him of profits.
- Defendants moved for summary judgment based on the submission agreement and the lack of secrecy or novelty.

## Issues

1. Whether the signed “new ideas” submission agreement barred claims based on implied contract, breach of confidence, or unjust enrichment, absent a valid patent.
2. Whether a plaintiff may recover for alleged use of an idea that was neither secret nor novel under a confidential-disclosure or quasi-contract theory.
3. Whether the documentary record left any genuine dispute of material fact precluding summary judgment.

## Decision

- The court granted summary judgment for the defendants in both related actions.
- The court held the signed submission agreement negated any implied obligation or liability for Chrysler’s consideration or use of the idea, except for liability under a valid patent.
- The court held the idea was not secret or novel and therefore could not support liability for misappropriation, breach of confidence, or unjust enrichment.
- The court concluded the undisputed documents established defendants’ entitlement to judgment as a matter of law.

## Legal Principles

- An express written idea-submission agreement disclaiming obligations and liability controls the parties’ relationship and precludes inconsistent implied-in-fact or implied-in-law duties, except as preserved by the agreement (such as liability under valid patents).
- Claims for unauthorized use of an idea premised on confidentiality or unjust enrichment generally require that the idea be secret or novel; public-domain or commonly known concepts are not protectable on those theories.
- Summary judgment is proper where the governing agreement and material facts are established by undisputed documents and the nonmovant fails to show a genuine dispute on elements essential to recovery.

## Conclusion

The court enforced Chrysler’s written submission release and held that, because the idea was already known in the industry and not protected by any patent, Hisel could not maintain implied-contract, confidential-disclosure, or unjust-enrichment claims, warranting summary judgment for defendants.


Hisel v. Chrysler Corp., 94 F. Supp. 996 (W.D. Mo. 1951)