Term: 2012
Docket: 11-1118
Jerry W. Gunn, Et Al., Petitioners v. Vernon F. Minton
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11-1118 GUNN, ET AL. V. MINTON DECISION BELOW: 355 S.W.3d 634 CERT. GRANTED 10/5/2012 QUESTION PRESENTED: Did the Federal Circuit depart from the standard this Court articulated in Grable & Sons Metal Products, Inc. u. Darue Eng'g & Mfg., 545 U.S. 308 (2005 ), for "arising under" jurisdiction of the federal courts under 28 U.S.C. § 1338, when it held that state law legal malpractice claims against trial lawyers for their handling of underlying patent matters come within the exclusive jurisdiction of the federal courts? Because the Federal Circuit has exclusive jurisdiction over appeals involving patents, are state courts and federal courts strictly following the Federal Circuit's mistaken standard, thereby magnifying its jurisdictional error and sweeping broad swaths of state law claims - which involve no actual patents and have no impact on actual patent rights - into the federal courts? LOWER COURT CASE NUMBER: 10-0141
In the case of Jerry W. Gunn, et al., v. Vernon F. Minton in 2012, the U.S Supreme Court ruled that legal malpractice claims related to patent law matters should be decided by state courts rather than federal courts. The dispute began when Vernon Minton sued his former attorneys for legal malpractice after losing a patent infringement lawsuit they had handled on his behalf. He argued that because the underlying issue involved a patent claim, it fell under exclusive federal jurisdiction as per Section 1338(a) of Title 28 of United States Code which grants federal courts exclusive jurisdiction over any civil action arising under any Act of Congress relating to patents. However, the court disagreed with this argument and held that while indeed patents are generally matters for federal law, not every question involving them falls within its purview; some may still belong in state court depending on how "substantial" or "established" their connection is to Federal Law - criteria established by Grable & Sons Metal Products Inc v Darue Engineering & Manufacturing (2005). In this case specifically where only past conduct was being evaluated and no future rights were at stake nor would there be binding precedent set for other cases involving Patent Law; thus making it more suitable for State Courts.
In the dissenting opinion for Jerry W. Gunn, et al., v. Vernon F. Minton, Justice Ginsburg disagreed with the majority's decision that federal courts have exclusive jurisdiction over legal malpractice claims involving patent law issues under 28 U.S.C §1338(a). She argued that state courts are fully capable of handling such cases and should not be precluded from doing so simply because a federal issue is embedded within a state-law claim. Furthermore, she contended that this ruling unnecessarily expands the scope of federal jurisdiction and could potentially flood federal courts with cases better suited to state court adjudication. In her view, only in instances where resolution of a federal question is necessary to resolve a case should it fall under exclusive federal jurisdiction.
