Gunn v. Minton

185 L. Ed. 2d 72 · Supreme Court of the United States · 2013

Facts

Minton's patent was invalidated in federal court due to his attorneys' failure to timely raise an "experimental use" defense. He then sued his attorneys for legal malpractice in Texas state court. Minton argued the state court lacked jurisdiction because the malpractice claim "arises under" federal patent law, requiring exclusive federal jurisdiction.

Issue

Does a state law legal malpractice claim, which requires resolving a hypothetical federal patent law question, "arise under" federal patent law, thereby triggering exclusive federal jurisdiction under 28 U.S.C. §1338(a)?

Holding

The Supreme Court held that Section 1338(a) does not deprive state courts of subject matter jurisdiction over Minton’s legal malpractice claim. The Texas Supreme Court's decision was reversed, and the case remanded.

Rule

For a state-law claim to "arise under" federal law for exclusive federal jurisdiction, it must necessarily raise a federal issue that is actually disputed, substantial to the federal system as a whole, and capable of resolution without disturbing the federal-state balance. The "substantiality" inquiry focuses on the importance of the issue to the federal system, not just the parties.

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Case brief last reviewed 2026-03-04. Prepared by CaseReader from the published opinion.