Byrne v. Wood, Herron & Evans, LLP

Under the Supreme Court’s decision in Christianson v. Colt Industries Operating Corp., 486 U.S. 800, 809, 108 S.Ct. 2166, 100 L.Ed.2d 811 (1988), federal jurisdiction under 28 U.S.C. § 1338 exists if “the plaintiffs right to relief necessarily depends on resolution of a substantial question of federal patent law, in that patent law is a necessary element of one of the well-pleaded claims.” We have followed Christian-son in subsequent cases involving legal malpractice, holding that federal jurisdiction exists, for example, “when the adjudication of the malpractice claim requires the court to…