Oil States Energy Services, LLC v. Greene's Energy Group, LLC

Oil States Energy Services sued Greene's Energy Group for patent infringement. Greene petitioned the Patent Trial and Appeal Board for inter partes review, which ultimately canceled Oil States' patent claims. Oil States appealed, arguing that the IPR process violated Article III and the Seventh Amendment by extinguishing private patent rights in a non-Article III tribunal without a jury. The Supreme Court granted certiorari. In a 7-2 decision delivered by Justice Thomas, the Court held that patents are public franchises granting public rights, and the IPR process falls within the adjudication of public rights by an executive agency, which is constitutional. The ruling affirmed that Congress may assign such review to the USPTO without violating the Constitution, preserving the administrative patent invalidation mechanism.

The Supreme Court affirmed the Federal Circuit, holding 7-2 that inter partes review does not violate Article III or the Seventh Amendment. Patents are public rights, and Congress may assign their adjudication to an administrative agency. The PTAB’s cancellation of patent claims was upheld as constitutional.

Whether the inter partes review process for canceling patents before the Patent Trial and Appeal Board violates the Constitution by extinguishing private property rights in an executive-branch tribunal without trial by jury under Article III and the Seventh Amendment.

The decision solidified the post-grant review framework under the America Invents Act, confirming the Patent Trial and Appeal Board as a legitimate alternative to district court litigation for challenging patent validity. It preserved a faster and more cost-effective mechanism for invalidating questionable patents, significantly influencing patent portfolio strategies and litigation dynamics. Critics warned it could devalue patents, while proponents argued it improved patent quality. The ruling has been widely cited in subsequent administrative law challenges involving agency adjudication of public rights.