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Jacobus Pharmaceutical Company, Inc. v. Catalyst Pharmaceuticals, Inc., et al.

Paid petition · United States Court of Appeals for the Eleventh Circuit, No. 20-13922 · judgment September 30, 2021


Dismissed · July 22, 2022
Pre-decision estimate: 2% cert probability

Before the decision, well below the 4.1% base rate, with no standout signals pointing toward a grant.

Question presented

Congress intended the Orphan Drug Act (ODA) to incentivize the development of drugs for the treatment of rare diseases. To be eligible for the incentives, a sponsor must obtain an orphan-drug designation from the Food and Drug Administration (FDA) for a drug that “is being or will be investigated for a rare disease or condition.” 21 USC § 360bb(a)(1). The primary incentive to do so is a period of exclusivity, which prevents FDA from approving another sponsor’s application for the “same drug for the same rare disease or condition” for seven years. 21 USC § 360cc(a). For the past 30 years, FDA regulations have interpreted ODA exclusivity to prohibit the agency only from approving a second “same drug” for the same “use” as the prior-approved drug. Here, the Eleventh Circuit created a split with the Fourth and D.C. Circuits, concluding that the ODA unambiguously foreclosed FDA’s regulation. FDA designated Respondent’s drug, Firdapse® (amifampridine), as an orphan drug to treat LambertEaton Myasthenic Syndrome (LEMS) and subsequently approved it for adults with LEMS (the only population Respondent sought approval to treat). FDA approved Petitioner’s drug, Ruzurgi® (amifampridine), for a pediatric population, which Firdapse® was not approved to treat. The Eleventh Circuit held that the ODA foreclosed this result. The question presented is: Does the ODA unambiguously foreclose FDA’s decades-long, consistent interpretation that the scope of orphan-drug exclusivity is tied to a drug’s approved use?

Counsel of record

For petitioner
Marisa Christina Maleck
King & Spalding LLP

For respondent
Philip J. Perry
Latham & Watkins, LLP

Case

Conference history

Proceedings

  1. Jul 22 2022
    Petition Dismissed - Rule 46.
  2. Jul 13 2022
    Joint stipulation for dismissal of the petition for a writ of certiorari pursuant to Rule 46 filed.
  3. Jul 11 2022
    Brief of Federal Respondents in opposition filed.
  4. May 31 2022
    Motion to extend the time to file a response is granted and the time for Catalyst Pharmaceuticals, Inc. to file a response is further extended to and including July 25, 2022.
  5. May 27 2022
    Motion of Catalyst Pharmaceuticals, Inc. to extend the time to file a response from June 24, 2022 to July 25, 2022, submitted to The Clerk.
  6. May 26 2022
    Motion to extend the time to file a response is granted and the time is further extended to and including July 11, 2022, for all respondents.
  7. May 25 2022
    Motion of the Solicitor General to extend the time to file a response from June 10, 2022 to July 11, 2022, submitted to The Clerk.
  8. May 23 2022
    Motion to extend the time to file a response is granted and the time for Catalyst Pharmaceuticals, Inc. to file a response is extended to and including June 24, 2022.
  9. May 20 2022
    Motion of Catalyst Pharmaceuticals, Inc. to extend the time to file a response from June 10, 2022 to June 24, 2022, submitted to The Clerk.
  10. May 05 2022
    Motion to extend the time to file a response is granted and the time is extended to and including June 10, 2022, for all respondents.
  11. May 04 2022
    Motion to extend the time to file a response from May 11, 2022 to June 10, 2022, submitted to The Clerk.
  12. Apr 07 2022
    Petition for a writ of certiorari filed. (Response due May 11, 2022)