Dr. Lakshmi Arunachalam v.
812 F.3d 290
3rd Cir.2016Background
- Dr. Lakshmi Arunachalam is plaintiff in several patent-infringement suits filed in D. Del., invoking 28 U.S.C. § 1338(a).
- Arunachalam moved to disqualify the District Judge, alleging the judge held mutual funds with holdings in some defendants; the judge denied the motions in identical March 28, 2015 orders.
- Arunachalam filed a mandamus petition in the Third Circuit seeking an order directing the District Judge’s disqualification.
- The Third Circuit recognized that appeals from final decisions in patent-infringement cases lie exclusively with the Federal Circuit under 28 U.S.C. § 1295(a)(1).
- The Third Circuit considered whether it had jurisdiction to grant mandamus relief and whether mandamus jurisdiction in patent cases is exclusive to the Federal Circuit.
- The court concluded it lacked mandamus jurisdiction and ordered transfer of the petition to the Federal Circuit under 28 U.S.C. § 1631, expressing no view on the petition’s merits.
Issues
| Issue | Arunachalam's Argument | Respondent's Argument | Held |
|---|---|---|---|
| Whether Third Circuit may issue mandamus to order district judge disqualified in patent-infringement actions | Third Circuit can exercise jurisdiction under the residual appeals statute and Medtronic to review interlocutory orders | Federal Circuit has exclusive appellate (and therefore mandamus) jurisdiction over patent cases under §1295(a) | Third Circuit lacks jurisdiction to issue mandamus; transfer to Federal Circuit required |
| Whether the residual jurisdiction statute (appeals to regional circuits) gives Third Circuit authority over mandamus petitions | Residual statute and Medtronic support Third Circuit jurisdiction for non-final orders | Residual statute applies to appeals, not mandamus; Medtronic is distinguishable (interlocutory appeal context) | Residual statute does not authorize mandamus review; Medtronic inapplicable here |
| Whether §1651(a) (writs "in aid of" jurisdiction) permits Third Circuit mandamus when it lacks appellate jurisdiction over final patent decisions | §1651(a) permits issuance to aid court’s jurisdiction | §1651(a) limits mandamus to aid the issuing court’s jurisdiction; Third Circuit will not have appellate jurisdiction over final patent appeals | §1651(a) bars Third Circuit from issuing mandamus because it lacks appellate jurisdiction over the underlying actions |
Key Cases Cited
- Christianson v. Colt Indus. Operating Corp., 486 U.S. 800 (1988) (Federal Circuit has exclusive jurisdiction over appeals in patent cases)
- In re Kensington Int’l Ltd., 353 F.3d 211 (3d Cir. 2003) (denial of disqualification reviewable by mandamus)
- In re BBC Int’l, Ltd., 99 F.3d 811 (7th Cir. 1996) (regional circuits lack mandamus jurisdiction where Federal Circuit has exclusive appellate jurisdiction)
- In re Princo Corp., 478 F.3d 1345 (Fed. Cir. 2007) (Federal Circuit recognizes exclusive mandamus jurisdiction in patent cases)
- Medtronic AVE, Inc. v. Advanced Cardiovascular Systems, Inc., 247 F.3d 44 (3d Cir. 2001) (regional circuit retained jurisdiction over interlocutory, nonfinal patent-related order; distinguished here)