The Supreme Court of the United States announced decisions in four cases today:

Association for Molecular Pathology v. Myriad Genetics, Inc., No. 12-398: Respondent Myriad Genetics, Inc. discovered the precise location and sequence of two human genes, BRCA1 and BRCA2, and then sought a number of patents. These patents, if valid, would give Myriad the exclusive right to isolate an individual’s BRCA1 and BRCA2 genes by breaking the bonds that connect the DNA to the rest of that individual’s genome. In addition, the patent would also give Myriad the exclusive right to synthetically create BRCA cDNA. As pertinent to today’s decision, the District Court had granted summary judgment to the plaintiffs on their claim that Myriad’s patents are invalid under 35 U.S.C. §101, but the Federal Circuit, on remand in light of the Court’s decision in Mayo Collaborative Services v. Prometheus Laboratories, Inc., 566 U.S. __ (2012), held that both the isolated DNA and cDNA were patent eligible under §101. Today, the Court affirmed in part and reversed in part, holding that a naturally occurring DNA segment is a product of nature and not patent eligible merely because it has been isolated, but that cDNA is patent eligible because it is not naturally occurring.

The Court's decision is available here.

American Trucking Assns., Inc. v. Los Angeles, No. 11-798: The Port of Los Angeles is a division of the City of Los Angeles, and is run by the City’s Board of Harbor Commissioners pursuant to a municipal ordinance known as a tariff. The Port’s tariff includes a criminal prohibition, whereby “no Terminal Operator shall permit access into any Terminal in the Port of Los Angeles to any Drayage Truck unless such Drayage Truck is registered under a Concession [Agreement].” The required standard concession agreement includes provisions that companies affix a placard on each truck with a phone number for reporting environmental or safety concerns, and submit a plan listing off-street parking locations for each truck when not in service. Petitioner American Trucking Associations, Inc. contended that these provisions in the concession agreement were pre-empted by Section 14501(c)(1) of the Federal Aviation Administration Authorization Act of 1994, which provides that “a State [or local government] may not enact or enforce a law, regulation, or other provision having the force and effect of law related to a price, route, or service of any motor carrier . . . with respect to the transportation of property.” The District Court held that the concession agreement was not pre-empted, and the Ninth Circuit affirmed. Today, the Court reversed in part, holding that the provisions in the concession agreement are pre-empted because they have “the force and effect of law.”

The Court's decision is available here.

Tarrant Regional Water Dist. v. Herrmann, No. 11-889: The federal Red River Compact, 94 Stat. 3305, allocates water rights among Texas, Oklahoma, Arkansas, and Louisiana – the states within the Red River basin. Petitioner Tarrant Regional Water District is a Texas agency that claimed that it is entitled under the Compact to acquire water from within Oklahoma, and that thus, Oklahoma laws restricting out-of-state diversions of water are pre-empted. Alternatively, Tarrant also argued that the Oklahoma laws are unconstitutional restrictions on interstate commerce. The District Court granted summary judgment for respondent Oklahoma Water Resources Board, and the Tenth Circuit affirmed. Today, the Court affirmed, holding that the Red River Compact does not pre-empt Oklahoma’s water statutes because the Compact creates no cross-border rights in its signatories for these statutes to infringe, and that Oklahoma’s laws do not run afoul of the Commerce Clause.

The Court's decision is available here.

United States v. Davila, No. 12-167: Respondent Anthony Davila entered a guilty plea to conspiracy to defraud the United States by filing false income tax returns. Davila contends that he entered this plea because during a pre-plea in camera hearing, a U.S. Magistrate Judge told him his best course was to plead guilty, in contravention of Fed. R. Crim. P. 11(c)(1), which requires that “[t]he court must not participate in [plea] discussions.” The Eleventh Circuit held that this violation of Rule 11(c)(1) warranted automatic vacatur of Davila’s guilty plea. The Court today vacated the Eleventh Circuit’s judgment, holding that Fed. R. Crim. P. 11(h) controls, under which vacatur of the plea is not in order if the record shows no prejudice to Davila’s decision to plead guilty.

The Court's decision is available here.