Oil States Energy Services, LLC v. Greene's Energy Group, LLC

Background

Two oilfield services companies were in a patent fight. One company owned a patent for wellhead equipment used in hydraulic fracturing and sued a competitor for infringement. The competitor asked the Patent Office to review and cancel the patent through inter partes review while the district court case continued. The Patent Trial and Appeal Board canceled the claims, the Federal Circuit affirmed, and the patent owner asked the Supreme Court to decide whether that administrative review is constitutional.

Reasoning

The Court considered whether Congress can let the Patent Office reconsider and cancel issued patents instead of having those disputes decided in an independent federal court, and whether a jury trial is required. The majority said patents are public franchises and that inter partes review is a permissible administrative “second look” under the public-rights doctrine. The Court held that IPR does not violate Article III and that the Seventh Amendment’s jury right does not independently bar IPR when Congress assigns the matter to an agency.

Real world impact

The ruling means the Patent Office may continue using inter partes review to cancel issued patent claims, giving challengers an administrative path alongside federal-court litigation. Patent owners can still seek judicial review in the Federal Circuit of final Board decisions, but patents face renewed administrative vulnerability. The Court emphasized its holding is narrow and did not resolve other constitutional questions like due process or retroactive application.

Dissents or concurrances

Justice Breyer (joined by two Justices) concurred, agreeing the public-rights approach suffices but warning the decision should not be read to allow agencies to decide all private-rights disputes. Justice Gorsuch (joined by the Chief Justice) dissented, arguing the ruling weakens judicial independence and that historically patent validity belonged to Article III courts.