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National Federation of Independent Business v. Sebelius | 567 U.S. 519 (2012)

In 2010, Congress passed a controversial health care law, the Patient Protection and Affordable Care Act (popularly known as ObamaCare, or the ACA). Shortly afterward, multiple parties, including business organizations, individuals, and 26 states, filed suit in district courts across the country to challenge the Act’s constitutionality. The results were fractured: some courts upheld some or all of the ACA, others declared part or all unconstitutional, some concluded offending provisions could be severed, and others argued that the Act couldn’t be challenged until someone was forced to pay the penalty.

In National Federation of Independent Business v. Sebelius, the National Federation of Independent Business, the State of Florida, and other plaintiffs sued in Florida federal court Katherine Sebelius, Secretary of the U.S. Department of Health and Human Services. The ACA is a massive piece of legislation, but the litigation challenged two key provisions: (1) the individual mandate, which requires individuals to purchase health insurance or pay a “penalty” and (2) the Medicaid expansion provision, which conditioned continued receipt of federal Medicaid funds on states expanding their eligibility requirements for the program.

The district court held that Congress had exceeded its authority in passing the individual mandate. The court concluded that the individual mandate was not severable and struck down the Act as a whole. On appeal, the Eleventh Circuit Court of Appeals affirmed that the individual mandate was unconstitutional. However, the court of appeals determined that the individual mandate was severable; so, the rest of the Act remained intact. The Supreme Court granted certiorari to resolve the split between the circuits.

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