In the 2011 case of Kappos v. Hyatt, the US Supreme Court ruled in favor of Gilbert P. Hyatt, an inventor who challenged a decision by the United States Patent and Trademark Office (USPTO). The dispute began when Hyatt's patent application was rejected by the USPTO for lack of adequate description. He then sought review in federal district court under Section 145 of the Patent Act, where he introduced new evidence not presented to the patent examiner during initial proceedings. The key issue before SCOTUS was whether such new evidence could be admitted or if it should have been presented earlier at administrative level. The Court held that there are no limitations on a patent applicant’s ability to introduce new evidence in a §145 proceeding beyond those already present in Federal Rules of Evidence and Civil Procedure; additionally, when new factual evidence is introduced under §145, de novo findings will be required - meaning fresh examination without deference to prior decisions made by lower courts or agencies.

In the dissenting opinion for Kappos v. Hyatt, Justice Sotomayor argued that the majority's decision to allow new evidence in a district court review of a patent application rejection undermines the role and expertise of Patent Office examiners. She contended that this approach could encourage applicants to withhold evidence from initial proceedings with hopes of presenting it later in more favorable forums. The ruling also contradicts previous decisions which limited judicial review to administrative records unless there was bad faith or procedural irregularities by agency officials. Furthermore, she disagreed with applying de novo standard instead of clear-error standard during reviews as it doesn't give due respect and deference to Patent Office’s factual findings.