National Federation of Independent Business v. Sebelius

Florida et al v. United States Department of Health and Human ServicesFlorida v. United States Department of Health and Human ServicesNFIB v. Sebelius2012 Supreme Court ruling26 states engaged in a joint actiona case then pendingAffordable Care Act decisiondecision to upholdDepartment of Health and Human Services, et al. v. Florida, et al.lawsuit brought by a number of state attorneys general
National Federation of Independent Business v. Sebelius, 567 U.S. 519 (2012), was a landmark United States Supreme Court decision in which the Court upheld Congress' power to enact most provisions of the Patient Protection and Affordable Care Act (ACA), commonly called Obamacare, and the Health Care and Education Reconciliation Act (HCERA), including a requirement for most Americans to have health insurance by 2014.wikipedia
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Patient Protection and Affordable Care Act

Affordable Care ActObamacareACA
National Federation of Independent Business v. Sebelius, 567 U.S. 519 (2012), was a landmark United States Supreme Court decision in which the Court upheld Congress' power to enact most provisions of the Patient Protection and Affordable Care Act (ACA), commonly called Obamacare, and the Health Care and Education Reconciliation Act (HCERA), including a requirement for most Americans to have health insurance by 2014.
In National Federation of Independent Business v. Sebelius, the Supreme Court ruled that states could choose not to participate in PPACA's Medicaid expansion, although it upheld the law as a whole.

John Roberts

John G. RobertsRobertsChief Justice Roberts
The Supreme Court, in an opinion written by Chief Justice John Roberts, upheld by a vote of 5 to 4 the individual mandate to buy health insurance as a constitutional exercise of Congress's taxing power.
Roberts has authored the majority opinion in several landmark cases, including Shelby County v. Holder, National Federation of Independent Business v. Sebelius, King v. Burwell, and Department of Commerce v. New York.

Medicaid

Medicaid fraudMedicaid expansionMedical Assistance
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. The Supreme Court granted certiorari to three cases, totaling 5½ hours of oral arguments: National Federation of Independent Business v. Sebelius (which consolidated a part of Florida v. Dept. of Health and Human Services) on the issues of the constitutionality of the individual mandate and the severability of any unconstitutional provisions, Dept. of Health and Human Services v. Florida on the issue of whether review was barred by the Anti-Injunction Act, and Florida v. Dept. of Health and Human Services on the matter of the constitutionality of the Medicaid expansion.
However, the Supreme Court of the United States ruled in National Federation of Independent Business v. Sebelius that states do not have to agree to this expansion in order to continue to receive previously established levels of Medicaid funding, and many states have chosen to continue with pre-ACA funding levels and eligibility standards.

National Federation of Independent Business

National Federation of Independent BusinessesNFIBFederation of Independent Business
A number of parties sued, including the National Federation of Independent Business, claiming that the sweeping reform law was unconstitutional for various reasons.
Under Danner's leadership, NFIB proved to be a driving force in opposing major governmental regulations; in 2012 it gained historical recognition as the only business association to challenge President Obama's Patient Protection and Affordable Care Act, as a party to the Supreme Court case National Federation of Independent Business v. Sebelius.

List of landmark court decisions in the United States

landmarklandmark decisionlandmark case
National Federation of Independent Business v. Sebelius, 567 U.S. 519 (2012), was a landmark United States Supreme Court decision in which the Court upheld Congress' power to enact most provisions of the Patient Protection and Affordable Care Act (ACA), commonly called Obamacare, and the Health Care and Education Reconciliation Act (HCERA), including a requirement for most Americans to have health insurance by 2014.

Individual mandate

employees are required to have health insuranceindividual health insurance mandatemandate
The Supreme Court, in an opinion written by Chief Justice John Roberts, upheld by a vote of 5 to 4 the individual mandate to buy health insurance as a constitutional exercise of Congress's taxing power. The Supreme Court granted certiorari to three cases, totaling 5½ hours of oral arguments: National Federation of Independent Business v. Sebelius (which consolidated a part of Florida v. Dept. of Health and Human Services) on the issues of the constitutionality of the individual mandate and the severability of any unconstitutional provisions, Dept. of Health and Human Services v. Florida on the issue of whether review was barred by the Anti-Injunction Act, and Florida v. Dept. of Health and Human Services on the matter of the constitutionality of the Medicaid expansion.
On June 28, 2012, the Supreme Court of the United States in the case of National Federation of Independent Business v. Sebelius upheld the health insurance mandate as a valid tax under the Taxing and Spending Clause of the Constitution.

Taxing and Spending Clause

Spending ClauseGeneral Welfare Clausetaxing and spending power
The Supreme Court, in an opinion written by Chief Justice John Roberts, upheld by a vote of 5 to 4 the individual mandate to buy health insurance as a constitutional exercise of Congress's taxing power. 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. David B. Kopel, an adjunct professor of constitutional law at University of Denver, said that Supreme Court ruling is the court's most important ruling in defining the limits of Congress's power under the Spending Clause, because this clause must, like Congress's other powers, conform to the principles of state sovereignty that are embodied in the United States Constitution, the Tenth Amendment and Eleventh Amendment.
Following that ruling, the Court later held by a 7–2 vote in National Federation of Independent Business v. Sebelius (2012) that Congress conditioning a state's receipt of the entirety of its federal Medicaid funds on whether said state elected to expand its Medicaid program in accordance with the Patient Protection and Affordable Care Act was an unconstitutionally coercive use of Congress's spending power.

Barack Obama

ObamaPresident ObamaPresident Barack Obama
In March 2010, President Barack Obama signed the Patient Protection and Affordable Care Act into law.
On June 28, 2012, the Supreme Court ruled by a 5–4 vote in National Federation of Independent Business v. Sebelius that the mandate was constitutional under the U.S. Congress's taxing authority.

Roger Vinson

C. Roger VinsonDistrict Court Judge VinsonFederal Judge Roger Vinson
On January 31, 2011, Judge Roger Vinson ruled that the mandatory health insurance "individual mandate"—the provision of Internal Revenue Code section 5000A imposing a "shared responsibility penalty" on nearly all Americans who fail to purchase health insurance—was outside the power of Congress.
In 2010, Vinson was assigned to hear a case, Florida et al v. United States Department of Health and Human Services, brought by a group of 26 states that was filed with support by 22 attorneys general and four governors challenging the constitutionality of the new Patient Protection and Affordable Care Act (PPACA), specifically its requirement that most individuals obtain medical insurance.

Necessary and Proper Clause

necessary and proper“necessary and proper” clauseArticle I, Section 8
A majority of the justices, including Chief Justice Roberts, agreed that the individual mandate was not a proper use of Congress's Commerce Clause or Necessary and Proper Clause powers, though they did not join in a single opinion.
In National Federation of Independent Business v. Sebelius (2012), the Supreme Court ruled that the individual mandate of the Patient Protection and Affordable Care Act cannot be upheld under the Necessary and Proper Clause.

Donald B. Verrilli Jr.

Donald Verrilli Jr.Donald VerrilliDonald B. Verrilli, Jr.
Since neither the government, represented by Solicitor General Donald Verrilli, nor the states, represented that day by Gregory G. Katsas of the law firm Jones Day, were willing to defend that position (which had been accepted by three of the twelve appellate court judges that heard the cases) the Court appointed Robert Long of the law firm Covington & Burling as amicus curiae to defend that position.
However, he was vindicated on June 28, 2012, when the court ruled that the individual mandate and most of the Act was constitutional, albeit as a tax and not as an exercise of Congress’s power under the Commerce Clause.

Health insurance mandate

individual mandatecompulsory insurance modelemployer mandate
On January 31, 2011, Judge Roger Vinson ruled that the mandatory health insurance "individual mandate"—the provision of Internal Revenue Code section 5000A imposing a "shared responsibility penalty" on nearly all Americans who fail to purchase health insurance—was outside the power of Congress.
Chief Justice John Roberts delivered the majority opinion in National Federation of Independent Business v. Sebelius, which upheld the Patient Protection and Affordable Care Act by a 5-4 vote.

Commerce Clause

interstate commerceInterstate Commerce Clauseinterstate
A majority of the justices, including Chief Justice Roberts, agreed that the individual mandate was not a proper use of Congress's Commerce Clause or Necessary and Proper Clause powers, though they did not join in a single opinion.
In Virginia v. Sebelius, Judge Henry Hudson overturned the law, claiming that failure to purchase health insurance coverage could not be considered economic activity, being rather economic "inactivity".

Severability

severability clauseseverablesevered
The Supreme Court granted certiorari to three cases, totaling 5½ hours of oral arguments: National Federation of Independent Business v. Sebelius (which consolidated a part of Florida v. Dept. of Health and Human Services) on the issues of the constitutionality of the individual mandate and the severability of any unconstitutional provisions, Dept. of Health and Human Services v. Florida on the issue of whether review was barred by the Anti-Injunction Act, and Florida v. Dept. of Health and Human Services on the matter of the constitutionality of the Medicaid expansion.
The severability doctrine is frequently used by the Supreme Court of the United States; for example, severability was a key issue in the Supreme Court's decisions related to National Federation of Independent Business v. Sebelius to determine if all or only parts of the Patient Protection and Affordable Care Act had to be deemed unconstitutional when one part was deemed as such.

Direct tax

direct taxesdirect taxationdirect
Further, the Court ruled that while the section 5000A penalty is treated as a tax for constitutional purposes, it is not a direct tax, and therefore is not required to be apportioned among the states according to population.
In National Federation of Independent Business v. Sebelius, the Supreme Court held that a penalty directly imposed upon individuals for failure to possess health insurance, though a tax for constitutional purposes, is not a direct tax.

Randy Barnett

Randy E. BarnettProfessor Randy BarnettR. Barnett
Georgetown Law professor Randy Barnett stated that by invalidating the withholding of existing Medicaid funding as unconstitutionally coercive the Supreme Court found an enforceable limit on the Spending Power of the federal government.
He was also involved in the famous Affordable Care Act case National Federation of Independent Business v. Sebelius.

Origination Clause

Article I, Section 7originate revenue billsrevenue raising bills
The joint dissent mentioned that "the Constitution requires tax increases to originate in the House of Representatives" per the Origination Clause, though that issue was not addressed by the majority opinion.
In 2012, the joint dissent in the U.S. Supreme Court case National Federation of Independent Business v. Sebelius mentioned that "the Constitution requires tax increases to originate in the House of Representatives" per the Origination Clause, though that issue was not addressed by the majority opinion.

Tax Anti-Injunction Act

Anti-Injunction ActTax Injunction Act
Chief Justice Roberts wrote the opinion of the Court on the Anti-Injunction Act and Congress's taxing power.
In the case of National Federation of Independent Business v. Sebelius, in which the constitutionality of the Patient Protection and Affordable Care Act was at issue, the U.S. Supreme Court upheld the constitutionality of the mandate imposed under that law.

Wickard v. Filburn

Roscoe FilburnWickard v FilburnWickard v. Filburn'', 317 U.S. 111 (1942)
However, he disagreed with the court's third, "substantial effects" test as established by Wickard v. Filburn, articulated within United States v. Morrison, and strengthened by Gonzales v. Raich.
In 2012, Wickard was central to arguments in National Federation of Independent Business v. Sebelius and Florida v. United States Department of Health and Human Services on the constitutionality of the individual mandate of the Affordable Care Act, with both supporters and opponents of the mandate claiming that Wickard supported their positions.

Tenth Amendment to the United States Constitution

Tenth Amendment10th AmendmentTenth
David B. Kopel, an adjunct professor of constitutional law at University of Denver, said that Supreme Court ruling is the court's most important ruling in defining the limits of Congress's power under the Spending Clause, because this clause must, like Congress's other powers, conform to the principles of state sovereignty that are embodied in the United States Constitution, the Tenth Amendment and Eleventh Amendment.
In National Federation of Independent Business v. Sebelius (2012), the Court ruled that the Patient Protection and Affordable Care Act (commonly referred to as the ACA or Obamacare) unconstitutionally coerced the states to expand Medicaid.

Supreme Court of the United States

United States Supreme CourtU.S. Supreme CourtSupreme Court
National Federation of Independent Business v. Sebelius, 567 U.S. 519 (2012), was a landmark United States Supreme Court decision in which the Court upheld Congress' power to enact most provisions of the Patient Protection and Affordable Care Act (ACA), commonly called Obamacare, and the Health Care and Education Reconciliation Act (HCERA), including a requirement for most Americans to have health insurance by 2014.

Health Care and Education Reconciliation Act of 2010

Health Care and Education Reconciliation Act111-1522010 health care reform bill
National Federation of Independent Business v. Sebelius, 567 U.S. 519 (2012), was a landmark United States Supreme Court decision in which the Court upheld Congress' power to enact most provisions of the Patient Protection and Affordable Care Act (ACA), commonly called Obamacare, and the Health Care and Education Reconciliation Act (HCERA), including a requirement for most Americans to have health insurance by 2014.

Healthcare reform debate in the United States

Health care reform debate in the United Stateshealth carehealth care reform debate
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.