The U.S. Supreme Court case Dickinson v. Zurko in 1998 revolved around the standard of review for decisions made by the Patent and Trademark Office (PTO). The court was asked to decide whether PTO's findings should be reviewed under an "arbitrary and capricious" standard or a more stringent "substantial evidence" standard, as used by courts when reviewing agency actions. Mary E. Zurko et al., who had been denied a patent, argued that their denial should be evaluated using the substantial evidence test rather than arbitrary and capriciousness one which is generally easier for agencies to meet. In its decision, the Supreme Court ruled that administrative rulings from PTO are indeed subject to an "arbitrary and capricious" review rather than a “substantial evidence” one because it falls under Administrative Procedure Act’s general provision instead of exception clause related with formal adjudications & rulemaking procedures on record after opportunity for hearing. This ruling has significant implications on how patent denials can be challenged in court; making it harder for inventors whose patents have been rejected by PTO to overturn those decisions through judicial appeal.

In the case of Dickinson v. Zurko, the dissenting opinion argued that the Administrative Procedure Act (APA) does not require courts to apply a stricter standard of review to findings made by administrative agencies like the Patent and Trademark Office (PTO). The dissenters believed that Congress intended for courts to use their own judgment when reviewing these decisions, rather than deferring heavily to agency expertise. They also pointed out inconsistencies in applying different standards of review across various federal agencies and warned against creating an overly complex legal system. Furthermore, they contended that there was no evidence suggesting patent examiners were better equipped than judges at determining facts related to patents. Therefore, they disagreed with majority's decision which held PTO’s factual determinations should be reviewed under APA’s “substantial evidence” standard instead of court's "clearly erroneous" standard.