National Federation of Independent Business v. Sebelius
| 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. Department of Health and Human Services, et al. |
| Docket nos. |
11-393 11-398 11-400 |
| Citations | 567 U.S. ___ (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) P50,423; 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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| Argument | |
| 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); Certiorari granted, 565 U.S. ___ (2011) |
| Holding | |
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(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, III-C), joined by Ginsburg, Breyer, Sotomayor, Kagan |
| Concurrence | Roberts (part IV), joined by Breyer, Kagan |
| Concurrence | Roberts (parts III-A, III-B, III-D) |
| Concur/dissent | Ginsburg, joined by Sotomayor; and Breyer, Kagan (parts I, II, III, 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) | |
(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.
National Federation of Independent Business v. Sebelius, 567 U.S. ___ (2012), 183 L. Ed. 2d 450, 132 S.Ct. 2566, was a landmarkUnited 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. 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.
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