Laboratory Corporation of America Holdings, Dba Labcorp v. Metabolite Laboratories, Inc.

Summary

The Court dismissed the writ of certiorari as improvidently granted without deciding whether the diagnostic patent claim impermissibly covered a natural phenomenon. Chief Justice Roberts did not participate. Justice Breyer, joined by Justices Stevens and Souter, dissented. He would have reached the merits despite concerns about preservation and the absence of a Federal Circuit ruling on the precise question, and would have held claim 13 invalid because it merely instructed users to obtain test results and recognize a natural correlation between elevated homocysteine levels and vitamin deficiencies.