Gunn v. Minton

Summary

The Supreme Court held that 28 U.S.C. § 1338(a) does not give federal courts exclusive jurisdiction over a state-law legal malpractice claim arising from an underlying patent case. Although resolving the malpractice claim required deciding a disputed patent-law issue, that issue was not substantial to the federal system as a whole and transferring such claims to federal court would improperly disrupt the federal-state balance. The Court reversed and remanded the judgment of the Supreme Court of Texas.

Holdings

1. Section 1338(a) does not deprive state courts of subject matter jurisdiction over a legal malpractice claim based on an underlying patent matter merely because resolving the claim requires consideration of a hypothetical patent issue.
2. The malpractice claim necessarily raised and actually disputed a federal patent question, but those two satisfied Grable requirements were insufficient to establish federal jurisdiction.

Questions Presented

1. Whether 28 U.S.C. § 1338(a) gives federal courts exclusive jurisdiction over a state-law legal malpractice claim whose resolution requires determining whether a patent-law argument would have succeeded in an earlier federal patent case.
2. Whether Minton's malpractice claim necessarily raised a substantial and actually disputed federal patent issue capable of resolution in federal court without disrupting the congressionally approved balance between federal and state judicial responsibilities.

Disposition

reversed_and_remanded