Christianson v. Colt Industries Operating Corp

In Christianson v. Colt Industries Operating Corp. (1988), 486 U.S. 800, 108 S.Ct. 2166, 100 L. Ed. 2d 811, the United States Supreme Court held that Section 1338 jurisdiction extends "only to those cases in which a well-pleaded complaint establishes either that federal patent law creates the cause of action or that the plaintiff's right to relief necessarily depends on resolution of a substantial question of federal patent law, in that patent law is a necessary element of one of the well-pleaded claims." Id. at 808-09. This two-part test requires a determination of whether "a state-law claim necessarily raises a stated federal issue, actually disputed and substantial, which a federal forum may entertain without disturbing any congressionally approved balance of federal and state judicial responsibilities." Grable & Sons Metal Prods. v. Darue Eng. & Mfg. (2005), 545 U.S. 308, 314, 125 S. Ct. 2363, 2368, 162 L. Ed. 2d 257. In determining whether patent jurisdiction exists in a given case, the United States Supreme Court has instructed that "arising under" jurisdiction "'must be determined from what necessarily appears in the plaintiff's statement of his own claim in the bill or declaration, unaided by anything alleged in anticipation or avoidance of defenses which it is thought the defendant may interpose.'" Christianson, 486 U.S. at 809 (quoting Franchise Tax Bd. of Cal. v. Constr. Laborers Vacation Trust (1983), 463 U.S. 1, 10, 103 S.Ct. 2841, 2846, 77 L. Ed. 2d 420. "Thus, a case raising a federal patent-law defense does not, for that reason alone, 'arise under' patent law, 'even if the defense is anticipated in the plaintiff's complaint, and even if both parties admit that the defense is the only question truly at issue in the case.'" Id. (quoting Franchise Tax Bd. of California, 463 U.S. at 14). As the United States Supreme Court noted in footnote 3 of Christianson, "on the other hand, merely because a claim makes no reference to federal patent law does not necessarily mean the claim does not 'arise under' patent law. J