Property I, Pages 106–108

Joyce v. General Motors Corporation

Supreme Court of Ohio, 1990


Plaintiff thought of a new idea to improve her company's performance. She submitted the suggestion, yet it rejected as being a duplicate as defendant had already submitted it. Defendant heard it from plaintiff telling someone who told someone else who told defendant. GM awarded defendant $12,000 for the idea, which he split with the other defendant who told him. Plaintiff sued for conversion for stealing her idea.

Procedural History:

Trial court gave a directed verdict for defendant, holding that ideas were not protected unless trademarked, copyrighted, or patented. Appellate court reversed, saying that a valuable idea could be subject to a conversion.


Are mere ideas protected property?


Courts have held that ideas themselves should be free for all to use until someone is able to translate such idea into a sufficiently useful form and be patented, trademarked, or copyrighted.


Ideas are not protected unless patented, copyrighted, or trademarked.


Court of appeals reversed and judgment of trial court reinstated.