National Federation of Independent Business v. Sebelius facts for kids
Quick facts for kids National Federation of Independent Business v. Sebelius |
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| Argued March 26–28, 2012 Decided June 28, 2012 |
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| Full case name | National 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. United States Department of Health and Human Services, et al. |
| Docket nos. | 11-393 11-398 11-400 |
| Citations | 567 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
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| Prior history | Act 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). |
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| Holding | |
| (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. Eleventh Circuit affirmed in part and reversed in part. |
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| Court membership | |
| Case opinions | |
| Majority | Roberts (Parts I, II, and III–C), joined by Ginsburg, Breyer, Sotomayor, Kagan |
| Plurality | Roberts (Part IV), joined by Breyer, Kagan |
| Plurality | Roberts (Parts III–A, III–B, and III–D) |
| Concur/dissent | Ginsburg, joined by Sotomayor; Breyer, Kagan (Parts I, II, III, and IV) |
| Dissent | Scalia, Kennedy, Thomas, Alito |
| Dissent | Thomas |
| Laws applied | |
| U.S. Const. art. I; 124 Stat. 119–1025 (Patient Protection and Affordable Care Act), Anti-Injunction Act | |
National Federation of Independent Business v. Sebelius, 567 U.S. 519 (2012), is a landmark 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, 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. 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.
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 power under the 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.
Contents
Background
In March 2010, President Barack Obama signed the Patient Protection and Affordable Care Act into law. A number of parties sued, including the National Federation of Independent Business, claiming that the sweeping reform law was unconstitutional for various reasons. 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.
District Court proceedings
The state of Florida filed a lawsuit against the United States Department of Health and Human Services, challenging the constitutionality of the law. 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. Vinson also held that the mandate could not be severed from the rest of the Affordable Care Act and struck down the entire act.
Eleventh Circuit appeal
The Department of Health and Human Services appealed to the 11th Circuit Court of Appeals. A three-judge panel issued a 2–1 ruling affirming Vinson's findings in part and reversing in part. The court affirmed the District Court's holding that the individual mandate was unconstitutional, but, contrary to the District Court's view, it held that the individual mandate could be severed, leaving the rest of the law intact. The government decided to not seek en banc review from the full Circuit and instead petitioned the United States Supreme Court to review the Eleventh Circuit's rulings.
Related cases
Other federal courts heard cases related to the Affordable Care Act that were not directly reviewed by the Supreme Court, but caused a divide regarding the law's constitutionality. Two federal judges appointed by President Bill Clinton upheld the individual mandate in 2010. Judge Jeffrey Sutton, a member of the Sixth Circuit Court of Appeals appointed by George W. Bush, was the first Republican-appointed judge to rule that the law is constitutional in June 2011, as part of a divided three-judge panel that upheld the law.
Subsequent cases
Sebelius was the centerpoint of the third legal challenge to the ACA to reach the Supreme Court in California v. Texas, heard in the 2020–21 term. In 2017, Congress passed the Tax Cuts and Jobs Act that reduced the health insurance requirement of the ACA to $0 from 2019 onward, effectively eliminating the individual mandate. Texas and several states sued the federal government, arguing on the basis of Sebelius that with mandate eliminated, the entire ACA was unconstitutional. A district court agreed with this, which was upheld on a challenge by California and other states to the Fifth Circuit, stepping in when the government declined to challenge the ruling. The Supreme Court agreed to hear the case to consider not only if the elimination of the individual mandate makes the ACA unconstitutional, but factors related to the severability of the individual mandate from other provisions in the ACA, as well as whether California has standing.
See also
- 2011 term opinions of the Supreme Court of the United States
- Burwell v. Hobby Lobby (2014)
- King v. Burwell (2015)
