2012年9月13日木曜日

Nat'l Fed'n of Indep. Bus. v. Sebelius, 132 S. Ct. 2566, 183 L. Ed. 2d 450 (2012)


Facts: 
Twenty-six states, as well as private individuals and organization of independent businesses, brought action against federal Health and Human Services (HHS), Treasury, and Labor Departments and their Secretaries, challenging constitutionality of Patient Protection and Affordable Care Act (PPACA).
The U.S. District Court granted summary judgment to defendants on state plaintiffs' claim that Act's expansion of Medicaid was unconstitutional, concluded that Act's individual mandate provision exceeded congressional authority and was not severable, and declared entire Act invalid.
The District Court further clarified its order and entered a stay pending appeal.
Defendants appealed, and state plaintiffs cross-appealed as to Medicaid expansion.
The Eleventh Circuit affirmed as to unconstitutionality of individual mandate, reversed determination of nonseverability, and affirmed as to constitutionality of Medicaid expansion. 
Certiorari was granted.

Holdings: 
The Supreme Court held that:
1.     Anti–Injunction Act did not bar pre-enforcement suit, abrogating Liberty Univ., Inc. v. Geithner, 671 F.3d 391; 
2.     individual mandate, imposing minimum essential coverage requirement under which certain individuals must purchase and maintain health insurance coverage, exceeded Congress's power under Commerce Clause, abrogating Thomas More Law Center v. Obama, 651 F.3d 529, and Seven–Sky v. Holder, 661 F.3d 1; 
3.     the individual mandate was a “tax” that was within Congress's taxing powers; 
4.     statutory provision giving Secretary of Health and Human Services (HHS) the authority to penalize States that chose not to participate in Act's expansion of Medicaid program exceeded Congress's power under the Spending Clause; and 
5.     the penalization provision was severable.

Affirmed in part and reversed in part.