Term: 2005
Docket: 04-607
Laboratory Corporation Of America Holdings, Dba Labcorp v. Metabolite Laboratories, Inc., Et Al.
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04-607 LABORATORY CORP. OF AMERICA V. METABOLITE LABORATORIES DECISION BELOW: 370 F3d 1354 LIMITED TO QUESTION 3 PRESENTED BY THE PETITION. ORDER OF 11/2/05: Having been advised by the Chief Justice that he now realizes that he should have recused himself from participation in this case, and does now recuse himself, the Court vacates its order of Monday, October 31, 2005. The Court has reconsidered the petition for certiorari, which is granted but limited to question three as presented in the petition. The Chief Justice has not participated in the vote to withdraw the order of October 31, 2005 or in the instant reconsideration of the petition for certiorari. CHIEF JUSTICE ROBERTS TOOK NO PART IN THE CONSIDERATION OR DECISION OF THIS CASE. DISMISSED AS IMPROVIDENTLY GRANTED. CERT. GRANTED 11/2/2005 QUESTION PRESENTED: 1. Whether liability can be imposed for willfully inducing patent infringement under 35 U.S.C. § 271(b) based solely on evidence that a party has disseminated a basic scientific fact to others. 2. Whether an express limitation in a patent claim can be ignored so as to allow the patent to cover the exact opposite of what was claimed. 3. Whether a method patent setting forth an indefinite, undescribed, and non-enabling step directing a party simply to "correlat[e]" test results can validly claim a monopoly over a basic scientific relationship used in medical treatment such that any doctor necessarily infringes the patent merely by thinking about the. relationship after looking at a test result. LOWER COURT CASE NUMBER: 03-1120
The case Laboratory Corporation of America Holdings, DBA LabCorp v. Metabolite Laboratories, Inc., et al., 2005 revolved around a patent dispute. Metabolite sued LabCorp for infringement of its patent which covered both a method for determining levels of homocysteine (an amino acid) in the body and correlating those levels with deficiencies in certain B vitamins. The Supreme Court initially agreed to hear the case but later dismissed it as improvidently granted without providing any reasons or judgment on merits. However, Justice Breyer dissented from this dismissal arguing that the patent was invalid because natural phenomena (like correlations between homocysteine and vitamin deficiency) cannot be patented under U.S law.
In the dissenting opinion for Laboratory Corporation of America Holdings v. Metabolite Laboratories, Inc., Justice Breyer argued that the patent in question should not have been granted because it covered a basic scientific relationship used in medical treatment decisions and thus violated principles of patent law. He contended that allowing such patents would inhibit future innovation rather than promote it as intended by the Constitution's Patent Clause. The justice expressed concern about potential negative impacts on public health if companies could monopolize basic, natural biological relationships through patents. Furthermore, he criticized the majority for dismissing LabCorp's appeal on procedural grounds instead of addressing these significant issues related to patentability and their implications for medical practice and research.
