Find Court Cases > Mayo Collaborative Services v. Prometheus Laboratories, Inc.

Mayo Collaborative Services v. Prometheus Laboratories, Inc.

Case Date: 12/07/2011
Docket No: none

Facts of the Case 

Prometheus Laboratories Inc. patented steps of testing for proper dosages of drug treatments used to treat gastrointestinal diseases like Crohn's disease, and sued the Mayo Clinic when it attempted to use its own, similar test. A federal judge invalidated the patents, holding that the patent couldn't cover the body's reaction to drugs. The U.S. Court of Appeals for the Federal Circuit, which specializes in patent issues, overturned the lower court order.

Question 

Can certain types of diagnostic medical tests can be patented?

Argument Mayo Collaborative Services v. Prometheus Laboratories, Inc. - Oral Argument  Download MP3 Conclusion  Decision: 9 votes for Mayo Collaborative Services, 0 vote(s) against Legal provision: Patent Act, Section 101

No. In a 9-0 decision, Justice Stephen J. Breyer wrote a unanimous opinion reversing the lower court and holding that the processes involved in this test are unpatentable laws of nature. The success of a patent application cannot rely on the art of the drafter. The “steps” Promethus added to their application are merely instructions to apply the laws of nature. Past Supreme Court decisions also support the concern that allowing patents on laws of nature would unnecessarily inhibit further discovery.