National Federation of Independent Business v. Sebelius

2012 United States Supreme Court case / From Wikipedia, the free encyclopedia

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National Federation of Independent Business v. Sebelius, 567 U.S. 519 (2012), is a landmark[2][3][4] United States Supreme Court decision in which the Court upheld Congress's power to enact most provisions of the Patient Protection and Affordable Care Act (ACA), commonly called Obamacare,[5][6] and the Health Care and Education Reconciliation Act (HCERA), including a requirement for most Americans to pay a penalty for forgoing health insurance by 2014.[7][8] The Acts represented a major set of changes to the American health care system that had been the subject of highly contentious debate, largely divided on political party lines.

Quick facts: National Federation of Independent Business v...
National Federation of Independent Business v. Sebelius
Argued March 26–28, 2012
Decided June 28, 2012
Full case nameNational Federation of Independent Business, et al. v. Kathleen Sebelius, Secretary of Health and Human Services, et al.; Department of Health and Human Services, et al. v. Florida, et al.; Florida, et al. v. Department of Health and Human Services, et al.
Docket nos.11-393
Citations567 U.S. 519 (more)
132 S. Ct. 2566; 183 L. Ed. 2d 450; 2012 U.S. LEXIS 4876; 80 U.S.L.W. 4579; 2012-2 U.S. Tax Cas. (CCH) ¶ 50,423; 109 A.F.T.R.2d (RIA) 2563; 53 Employee Benefits Cas. (BNA) 1513; 23 Fla. L. Weekly Fed. S 480
Case history
PriorAct declared unconstitutional sub. nom. Florida ex rel. Bondi v. US Dept. of Health and Human Services, 780 F. Supp. 2d 1256 (N.D. Fla. 2011); affirmed and reversed in parts, 648 F.3d 1235 (11th Cir. 2011); cert. granted, 565 U.S. 1033 (2011), 565 U.S. 1034 (2011).
(1) The Tax Anti-Injunction Act does not apply because the Patient Protection and Affordable Care Act (ACA)'s labeling of the individual mandate as a "penalty" instead of a "tax" precludes it from being treated as a tax under the Anti-Injunction Act.

(2) The individual mandate provision of the ACA functions constitutionally as a tax, and is therefore a valid exercise of Congress's taxing power.

(3) Congress exceeded its Spending Clause authority by coercing states into a transformative change in their Medicaid programs by threatening to revoke all of their Medicaid funding if they did not participate in the Medicaid expansion, which would have an excessive impact on a state's budget. Congress may withhold from states refusing to comply with the ACA's Medicaid expansion provision only the additional funding for Medicaid provided under the ACA.[1]

Eleventh Circuit affirmed in part and reversed in part.
Court membership
Chief Justice
John Roberts
Associate Justices
Antonin Scalia · Anthony Kennedy
Clarence Thomas · Ruth Bader Ginsburg
Stephen Breyer · Samuel Alito
Sonia Sotomayor · Elena Kagan
Case opinions
MajorityRoberts (Parts I, II, and III–C), joined by Ginsburg, Breyer, Sotomayor, Kagan
PluralityRoberts (Part IV), joined by Breyer, Kagan
ConcurrenceRoberts (Parts III–A, III–B, and III–D)
Concur/dissentGinsburg, joined by Sotomayor; Breyer, Kagan (Parts I, II, III, and IV)
DissentScalia, Kennedy, Thomas, Alito
Laws applied
U.S. Const. art. I; 124 Stat. 119–1025 (Patient Protection and Affordable Care Act)

The Supreme Court, in an opinion written by Chief Justice John Roberts, upheld by a vote of 5–4 the individual mandate to buy health insurance as a constitutional exercise of Congress's Taxing and Spending Clause (taxing power). A majority of the justices, including Roberts, agreed that the individual mandate was not a proper use of Congress's Commerce Clause or Necessary and Proper Clause powers, although they did not join in a single opinion. A majority of the justices also agreed that another challenged provision of the Act, a significant expansion of Medicaid, was not a valid exercise of Congress's spending power, as it would coerce states to either accept the expansion or risk losing existing Medicaid funding.