Kelly v. United States
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Kelly v. United States and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).
Summary
A short, plain-English overview of Kelly v. United States.
The Supreme Court ruled that judicial review is not available for the Patent Office's decision to institute inter partes review when challenged under the time-bar provision of § 315(b). The Court emphasized that § 314(d) precludes such review, reinforcing the statute's purpose to efficiently eliminate invalid patent claims. This decision aligns with the Court's previous interpretation in Cuozzo Speed Technologies, LLC v. Lee.
Holding
The single most important “bottom line” of what the Court decided in Kelly v. United States.
The Court held that § 314(d) precludes judicial review of the agency's application of § 315(b)'s time prescription.
Constitutional Concepts
These are the Constitution-related themes that appear in Kelly v. United States. Click a concept to see other cases that involve the same idea.
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Why Administrative Law is relevant to Kelly v. United States
The case revolves around the limits of judicial review of agency decisions, specifically the Patent Office's decision to institute inter partes review.
Syllabus excerpt (verbatim)Section 314(d) precludes judicial review of the agency's application of § 315(b)'s time prescription.
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Why Judicial Review is relevant to Kelly v. United States
The Court's decision focuses on whether judicial review is available for the agency's decision to institute inter partes review under certain statutory conditions.
Syllabus excerpt (verbatim)Section 314(d) bars review at least of matters 'closely tied to the application and interpretation of statutes related to' the institution decision.
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Why Preemption is relevant to Kelly v. United States
The decision involves the interpretation of federal statutes governing agency authority, which may preempt judicial review.
Syllabus excerpt (verbatim)Congress designed inter partes review to weed out bad patent claims efficiently. Allowing § 315(b) appeals, however, would unwind agency proceedings.
Key Quotes
Short excerpts from the syllabus in Kelly v. United States that support the summary and concepts above.
"Section 314(d) precludes judicial review of the agency's application of § 315(b)'s time prescription."
"Congress designed inter partes review to weed out bad patent claims efficiently."
"A § 315(b) challenge easily meets that measurement."
