Christianson v. Colt Industries Operating Corp.

486 U. S. 800

June 17, 1988

In an antitrust suit against Colt, both principal charges could be resolved on the basis of patent law. The Seventh Circuit and the Federal Circuit ended up playing a hilarious ping pong game over who had jurisdiction, with each insisting the other did. The law said the Federal Circuit had jurisdiction for cases “arising under” patent law, but the Federal Circuit contended that the case really arose under antitrust law, and that patent law was an ancillary and possibly even unnecessary feature of the lawsuit. They ended up issuing a ruling anyway, just to stop the ping pong nonsense

The Supreme Court ruled unanimously that the Federal Circuit had no jurisdiction. The “arising under” language for patent law was meant to mirror similar language granting all federal courts jurisdiction for cases “arising under” federal law. As Brennan explained, cases arose under federal law only when the federal law was the true basis for the complaint. Because there were grounds for finding antitrust violations without reference to patent law at all, there was no way the suit against Colt could be said to arise under patent law. Brennan added that once the Federal Circuit initially determined that it lacked jurisdiction, the Seventh Circuit should have considered itself bound to take the case. He chided the Federal Circuit for capitulating and finally making a ruling.

Stevens, joined by Blackmun, wrote a concurrence to note that the question of the Federal Circuit’s jurisdiction should be decided at the time of appeal, given that the initial complaint can be extensively modified during the course of a case’s time in District Court. This is the goofiest jurisdiction case I’ve read yet, and I hope future ones will have the same kind of weird humor about them.

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