Laboratory Corp. of America Holdings v. Metabolite Laboratories, Inc.
The Supreme Court dismissed this case without deciding it, ruling that the writ of certiorari had been "improvidently granted" — meaning the Court decided not to answer the patent question it had originally agreed to take up.
The dismissal leaves in place a lower court ruling that upheld a medical testing company's patent covering the link between elevated homocysteine levels and vitamin deficiencies, and it leaves unresolved a major question about how far patent law can go in covering basic scientific relationships.
“The writ of certiorari is dismissed as improvidently granted.”
The entirety of the Court's ruling, which decided nothing on the merits.
How it got here: A jury and district court found the patent claim valid and infringed; the Federal Circuit affirmed; the Supreme Court granted review but then dismissed the writ without deciding.
The Case in Depth
What happened
Researchers found that elevated homocysteine levels in blood correlate with deficiencies of two vitamins, folate and B12, and patented a testing-and-correlating method built on that discovery. LabCorp, which had licensed the patent, switched to a different testing method (made by Abbott) and stopped paying royalties. The patent holders, Metabolite Laboratories and Competitive Technologies, sued LabCorp for infringement and breach of contract.
The question before the Court
Could a lab testing company be forced to pay for patenting the basic medical link between high homocysteine levels and vitamin deficiency?
The Court's answer
The Court did not answer this question. It dismissed the writ of certiorari as improvidently granted, meaning it declined to rule on whether the patent claim validly covered the correlation between homocysteine and vitamin deficiency. That left the Federal Circuit's ruling upholding the patent - and the injunction against LabCorp - in place.
Three justices dissented, arguing the Court should have decided the issue since it was fully briefed and important to medical practice. In their view, the patent claim did nothing more than dress up a basic biological correlation as a testing-and-correlating "process," and should have been struck down as an unpatentable natural phenomenon.
Curious how the Court got there? See the step-by-step legal reasoning →
Why it matters
Doctors and labs that order or interpret homocysteine tests remain subject to the patent and its licensing terms, since the Federal Circuit's ruling upholding the patent stands. The broader question of whether companies can effectively patent basic biological correlations remains unresolved, leaving continued uncertainty for medical researchers, lab companies, and patent holders in similar situations.
What changes now
Because the Court dismissed the writ rather than ruling on the merits, the Federal Circuit's decision upholding the patent claim and the injunction against LabCorp stays in place. The underlying legal question about patenting scientific correlations remains unresolved by the Supreme Court, leaving lower courts and patent holders without new guidance from this case; the issue could resurface in a future case.
What this does not decide
This order does not decide whether the patent claim validly covers a natural scientific relationship or is instead an unpatentable law of nature. The Court reached no conclusion on the merits at all, despite full briefing; only the dissenting justices addressed that question.
Concurrences and dissents
Dissent — Justice Breyer
Justice Breyer argued the Court should have decided the case rather than dismissing it, since the question was fully briefed, not unusually difficult, and important to medical practice. On the merits, he concluded that patent claim 13 covers nothing more than an unpatentable natural correlation between homocysteine levels and vitamin deficiency, dressed up as a 'testing and correlating' process, and that it adds nothing of patentable substance beyond that natural relationship.
How the Court got there
The legal reasoning, step by step
- The per curiam order itself provided no explanation for the outcome; it simply stated that the writ of certiorari was dismissed as improvidently granted, without addressing the patent-law question the Court had agreed to hear.
- The dissent suggested one possible procedural reason the majority may have hesitated: LabCorp had not specifically invoked the Patent Act's eligibility provision, Section 101, when arguing before the lower courts, even though it had raised the substance of the argument.
- Because the majority offered no reasoning, the underlying legal question - whether a patent claim covering only a testing step and a 'correlating' step can validly monopolize a natural biological relationship - was left completely undecided by the Court.
- As a result, the Federal Circuit's earlier decision, which had upheld the patent claim as valid and infringed, and the injunction against LabCorp, remained in effect without any Supreme Court review of their reasoning.