Diamond v. Chakrabarty

The Court began with § 101's broad text, which authorizes patents for “any new and useful process, machine, manufacture, or composition of matter.” Read in their ordinary sense, “manufacture” includes articles made from materials with new qualities, properties, or combinations, while “composition of matter” encompasses compositions of two or more substances and composite articles. Congress's use of the word “any” confirmed that these categories were meant to have wide scope.

The legislative history reinforced that reading. The 1952 Patent Act retained the broad language traceable to the Patent Act of 1793, changing only “art” to “process.” The accompanying committee reports stated that patentable subject matter includes “anything under the sun that is made by man.” Broad statutory language was especially appropriate because important inventions often cannot be anticipated when Congress legislates.

Section 101 nevertheless excludes laws of nature, physical phenomena, and abstract ideas. A newly discovered natural mineral, a plant found in the wild, Newton's law of gravity, and Einstein's equation are not patentable because they are manifestations of nature available to all. But Chakrabarty did not claim a natural phenomenon; he claimed a bacterium created through human intervention, with a distinctive character and useful capacity to degrade multiple oil components.

Funk Brothers Seed Co. v. Kalo Inoculant Co. did not control because the patentee there merely combined naturally occurring bacterial species that continued to perform their natural functions. Chakrabarty, by contrast, created a bacterium with markedly different characteristics from any bacterium found in nature. The relevant line is therefore between nature's handiwork and a human-made invention, not between living and inanimate matter.

The 1930 Plant Patent Act was enacted against the view that plants were products of nature and because plant varieties could be difficult to describe adequately in writing, as the patent laws ordinarily require. Congress addressed both problems by recognizing the inventive work of plant breeders and relaxing the description requirement for plant patents. Nothing in the Act's text or legislative history showed that Congress adopted a general rule excluding all living things from “manufacture” or “composition of matter.”

The Court rejected the Government's reliance on a statement by the Secretary of Agriculture that patent laws were understood to cover only inanimate nature. That statement was not controlling, and the committee reports instead emphasized a distinction between a product created wholly by nature and a cultivated plant variety that could not be reproduced by nature unaided by humans. Thus, Congress treated human contribution—not whether an object was alive—as the pertinent distinction.

The 1970 Plant Variety Protection Act likewise did not narrow § 101. It extended specialized protection to sexually reproduced plant varieties because such varieties could then be reproduced true-to-type. Its exclusion of bacteria contained no stated rationale and did not demonstrate an intent to amend or limit § 101. The exclusion could reflect that bacteria were not plants under the earlier plant-patent statute or that the Patent Office had already issued microorganism patents under § 101.

The Government argued that genetic engineering was unforeseen when § 101 was enacted and that Congress, rather than the Court, should decide whether living engineered organisms should receive patent protection. The Court agreed that Congress defines the limits of patentability, but held that Congress had already done so through § 101's broad language. The judiciary's role was to apply that language, not to withhold coverage merely because a particular technology was novel.

Parker v. Flook did not require a different result. Flook held that a mathematical algorithm remained unpatentable even when linked to a particular use because it fell within the exclusion for ideas or natural phenomena. It did not establish that all inventions unforeseen by Congress are categorically ineligible. Such a rule would conflict with the patent system's purpose of encouraging advances that push technological frontiers.

Arguments that genetic research could create grave risks—such as pollution, disease, loss of genetic diversity, or diminished respect for human life—raised substantial policy concerns, but they did not answer the statutory question. Courts lack the institutional competence to balance those competing scientific, social, and economic interests. Congress and the Executive may regulate genetic research or amend § 101, but absent such action the statute's language covers Chakrabarty's invention.