Cuozzo Speed Technologies, LLC v. Lee
The Court ruled that a federal law making the Patent Office's decision to start a patent-cancellation review "final and nonappealable" means courts generally cannot second-guess that threshold decision, at least for ordinary disputes about how the review statute applies.
The Court also upheld a Patent Office rule that lets the agency interpret patent claims using their broadest reasonable meaning during these reviews, rather than the narrower everyday meaning federal courts use, because Congress gave the agency room to make that choice.
How it got here: The Patent Trial and Appeal Board canceled the patent claims; the Federal Circuit affirmed, rejecting Cuozzo's challenges; Cuozzo sought Supreme Court review.
The Case in Depth
What happened
Cuozzo Speed Technologies held a patent on a GPS-linked speedometer display that shows drivers when they exceed the speed limit. Garmin asked the Patent Office to cancel several of the patent's claims as obvious in light of earlier inventions. The Patent Office agreed to review not just the claim Garmin specifically targeted but two related claims it viewed as logically tied to that challenge, and ultimately canceled all three.
The question before the Court
When the Patent Office decides to launch a review of an existing patent, can a company fight that threshold decision in court, and can the agency use a broader standard than judges do to interpret the patent's claims?
The Court's answer
No, and yes. The Court held that the law's statement that the Patent Office's decision to start a review "shall be final and nonappealable" bars courts from reviewing that threshold decision when the challenge is an ordinary dispute about how the review statute applies, like Cuozzo's claim that the petition against it wasn't specific enough. That bar does not necessarily extend to constitutional claims or to arguments that the agency acted far outside its statutory authority.
On the second question, the Court said yes — the Patent Office was allowed to adopt its rule using the broadest reasonable reading of patent claims. Congress gave the agency authority to write rules governing these reviews without specifying which interpretive standard to use, so the agency's choice, which has deep roots in patent practice, was a reasonable exercise of that authority.
Curious how the Court got there? See the step-by-step legal reasoning →
Why it matters
Patent owners facing a challenge before the Patent Trial and Appeal Board generally cannot get a court to review the agency's initial decision to open a review, making it harder to stop a cancellation proceeding early. Because the agency can read claims more broadly than courts do, patents are more vulnerable to cancellation in these proceedings than in ordinary patent lawsuits, affecting inventors, patent licensors, and companies that rely on patent challenges to clear the field of competitors' patents.
What changes now
This is a final merits decision, so no further proceedings on these two questions are expected in this case. Patent challengers and patent owners must continue operating under this framework: institution decisions in inter partes review remain largely shielded from routine court challenge, and the agency's broader claim-construction standard remains in effect for these proceedings, shaping strategy in the many patent-review cases the Patent Office handles each year.
What this does not decide
The Court expressly did not decide whether courts could review claims that the Patent Office acted outside its statutory authority in more serious ways, such as canceling a patent on a ground not permitted in that type of review, or claims raising constitutional questions. It limited its holding to ordinary disputes closely tied to the review-institution statute itself.
Concurrences and dissents
Concurrence — Justice Thomas
Justice Thomas joined the Court's opinion in full but wrote separately to note that the decision does not rest on Chevron's premise that statutory ambiguity implies a delegation of lawmaking power to agencies. He reiterated his view that the Court should reconsider Chevron deference in an appropriate future case, though he found no constitutional problem here because Congress expressly gave the Patent Office rulemaking authority.
Dissent in part — Justice Alito
“If a provision can reasonably be read to permit judicial review, it should be.”Alito's central objection that the majority did not give enough weight to the presumption favoring judicial review.
Justice Alito agreed that the Patent Office's broadest-reasonable-construction rule was lawful, but dissented from the ruling that courts cannot review the agency's decision to start a review. He argued the word "nonappealable" only blocks an immediate appeal of that preliminary decision, not review once folded into an appeal from the agency's final decision, and warned the majority's reading could let the agency exceed clear statutory limits without any judicial check.
How the Court got there
The legal reasoning, step by step
- The Court read the statute's text, which calls the Patent Office's decision to start a patent review "final and nonappealable," as a strong signal that Congress meant to cut off routine court challenges to that threshold decision.
- Applying the presumption favoring judicial review — the default rule that courts assume Congress wants agency action to be reviewable unless it says otherwise clearly — the Court found that presumption overcome here by the statute's text, its place in a broader scheme built around a separate right to appeal final decisions, and the history of similar earlier patent-review provisions.
- The Court limited its holding to challenges that are closely tied to the specific statutory provisions governing whether to start a review, leaving open whether courts could still review constitutional claims or claims that the agency exceeded its authority in a way that reaches well beyond the review-initiation statute.
- Turning to the claim-interpretation rule, the Court applied the Chevron framework, under which courts let an agency fill a genuine gap or ambiguity in a statute with a reasonable rule tied to the law's purpose. It found the review statute never specified which claim-interpretation standard applies, leaving a gap for the agency to fill.
- The Court concluded the agency's chosen standard — interpreting claims as broadly as reasonably possible — was a reasonable policy choice given the mixed judicial-and-administrative nature of these reviews, the agency's century-long use of that standard elsewhere, and the patent holder's ability to move to narrow its claims during the process.
Doctrinal impact
Cases affected by this decision
Reaffirms Chevron U.S.A. Inc. v. Natural Resources Defense Council, Inc. (467 U.S. 837)
Reaffirmed as the framework for letting agencies fill statutory gaps with reasonable rules.
Distinguishes Lindahl v. Office of Personnel Management (470 U.S. 768)
Used to support limiting judicial review here, while the dissent read it as supporting broader review.
Reaffirms Block v. Community Nutrition Institute (467 U.S. 340)
Relied on for the standard that clear and convincing evidence can overcome the presumption favoring judicial review.