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Supreme Court of the United StatesPatent Eligibility
Decided 1980

Diamond v. Chakrabarty

447 U.S. 303 (1980)· Docket No. No. 79-136· Opinion by Chief Justice Warren E. Burger (5-4 Majority)
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Synthetic Biology, Genetics & Bio-Jurisprudence
Niche Legal Sub-Discipline Tags:
GOOD LAW · BINDING AUTHORITY

Canonical Supreme Court authority establishing patent eligibility for genetically engineered organisms and synthetic biology.

OPERATIVE SIGNALS & RISK DISSECTION
BINDING PRECEDENT
Operative Judicial Rule

A live, human-made micro-organism is patentable subject matter under 35 U.S.C. § 101 because it has markedly different characteristics from any found in nature.

Practical Tech Impact

Enables patent exclusivity for engineered synthetic genomes, chimeric antigen receptors, and modified biological constructs.

Precedential Standing & Risk

Binding SCOTUS Bedrock (Good Law)

Formal Judicial Holding:

“A live, human-made micro-organism is patentable subject matter under 35 U.S.C. § 101. Congress intended patentable subject matter to 'include anything under the sun that is made by man.'”

Factual Background:

Ananda Chakrabarty, a microbiologist at General Electric, engineered a genetically modified bacterium (of the genus Pseudomonas) capable of breaking down multiple components of crude oil. The USPTO patent examiner rejected the claims on the grounds that microorganisms are 'products of nature' and living things are not patentable subject matter under 35 U.S.C. § 101.

Procedural Posture & Issue:

On writ of certiorari to the United States Court of Customs and Patent Appeals, which had reversed the USPTO's rejection of patent claims to a live, human-engineered bacterium.

Issue: Whether a live, human-made, genetically engineered micro-organism is a patentable 'manufacture' or 'composition of matter' under 35 U.S.C. § 101.

Judicial Reasoning & Statutory Construction

  • 1.Broad Statutory Intent: The language of 35 U.S.C. § 101 uses broad terms ('manufacture', 'composition of matter') modified by the expansive term 'any'. The Committee Reports accompanying the 1952 Patent Act confirm Congress intended statutory subject matter to encompass 'anything under the sun that is made by man.'
  • 2.Distinction from Natural Products: Chakrabarty's micro-organism possesses markedly different characteristics from any found in nature, possessing the capacity for oil degradation that is not possessed by any naturally occurring bacteria.
  • 3.Living vs Inanimate Is Irrelevant: The relevant distinction is not between living and inanimate things, but between products of nature (whether living or not) and human-made inventions.
Doctrinal Significance & Precedential Legacy:

Chakrabarty is the bedrock precedent that launched the modern global biotechnology and synthetic biology industries. It established that genetic engineering, recombinant DNA, and human-modified biological organisms qualify for patent protection, forming the legal baseline for CRISPR-Cas9 patents, mRNA vaccines, and synthetic organisms.

Statutory Hooks & Precedents Cited:
35 U.S.C. § 101 (Inventions Patentable)Plant Patent Act of 1930 (35 U.S.C. § 161)Funk Brothers Seed Co. v. Kalo Inoculant Co., 333 U.S. 127 (1948)Hartranft v. Wiegmann, 121 U.S. 609 (1887)
Downstream Impact:
Spawned the multi-trillion dollar commercial biotechnology and biopharmaceutical industry.Applied and limited in Association for Molecular Pathology v. Myriad Genetics (2013), which barred patents on unmanipulated isolated human genomic DNA.
Canonical Bluebook / APA Citation:Official CourtListener / Justia Repository

Diamond v. Chakrabarty, 447 U.S. 303 (1980).