How courts read patent claims
Teva Pharmaceuticals USA v. Sandoz
In brief
The Federal Circuit must respect trial judges’ factual findings in patent-claim interpretation unless they are clearly wrong; the Supreme Court wiped out its ruling (vacated it) and sent the case back (remanded).
- Where it stands
- Decided
Decided 7-2 · January 20, 2015 · Opinion by Justice Breyer
- What it’s about
- Teva Pharmaceuticals and Sandoz disputed whether the Federal Circuit could recheck facts a trial judge found while interpreting a patent claim from scratch or overturn them only if clearly wrong.
- Who it affects
- For this case, the Federal Circuit must leave the district judge’s factual findings in place unless they are clearly wrong.
Summary: written with AI from the case record.
What it's about
The Supreme Court required the latter for those findings, wiped out the appeals court’s ruling (vacated it), and sent the case back (remanded).
The dispute concerned the difference between factual findings made during patent-claim interpretation and the meaning assigned to the claim.
Question presented
Whether a district court's factual finding in support of its construction of a patent claim term may be reviewed de novo , as the Federal Circuit requires (and as the panel explicitly did in this case), or only for clear error, as Rule 52(a) requires.
What the Court decided
Holding
When reviewing a district court’s resolution of subsidiary factual matters made in the course of its construction of a patent claim, the Federal Circuit must apply a “clear error,” not a de novo, standard of review. 723 F. 3d 1363, vacated and remanded.
- Result
- Vacated
The Court's reasoning
The Court said the Federal Circuit must respect a trial judge’s factual findings made while interpreting a patent claim, rather than reconsider those facts from scratch.
The vote
What's next
The Federal Circuit must take another look at the case and leave the district court’s factual findings in place unless they are clearly wrong.
Documents
Docket activity
New analysis added
AI analysis generated: Impact Analysis
AI analysis generated: Opinion Summary
New analysis added
AI analysis generated: Case Briefing
Show 5 moreShow fewer
AI analysis generated: Decision Record
Case data updated: summary, question_presented, generation_metadata
Case data updated: question_presented, extraction_metadata
Opinion added: Opinion
Brief added: Questions Presented
More questions
- Why did Justice Thomas disagree?
- He argued that patent-claim interpretation is a legal conclusion, not a factual finding covered by the rule, so the Federal Circuit could review it from scratch.
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.