The following are summaries of opinions issued by the Fifth Circuit in May 2023. The summaries are overviews of particular aspects of the opinions; please review the entire opinions.
JURISDICTION: In an ancillary action to enforce a settlement agreement, parties could not collaterally challenge jurisdiction in the original proceeding settled and could sue only to enforce the settlement agreement.
Nat’l Oilwell Varco, L.P. v. Auto-Dril, Inc., No. 21-40648, 2023 WL 3411189 (5th Cir. May 12, 2023).
In the original action, National Oilwell Varco (“NOV”) sued Auto-Dril for patent infringement. The parties settled, with Auto-Dril purchasing a license from NOV and both parties releasing all claims against each other. The district court retained jurisdiction “to interpret and enforce” the settlement agreement.
Later, the parties sued each other to enforce…