Gunn v. Minton (2012)
- Docket
- 11-1118
- Decided
- 2012-01-01
Summary
Question: Do the federal courts have exclusive jurisdiction in any cases that involve patent law, even when the patent issue is not the primary issue in the case? Conclusion: No. Chief Justice John G. Roberts, Jr., writing for a unanimous Court, reversed the lower court and remanded. The Supreme Court applied Grable & Sons Metal Products, Inc. v. Darue Engineering & Mfg. , which provided that a case only arises under federal patent law when it "necessarily raise[s] a stated federal issue, actually disputed and substantial, which a federal forum may entertain without disturbing any congressionally approved balance of federal and state judicial responsibilities." The Court held that Minton failed to show that the federal issue in the case carried the necessary significance. The need to decide a hypothetical patent case is not substantial enough to deprive the state court of jurisdiction. A state court decision in a state law malpractice case relating to patent law will not substantially affect federal patent law.