Introduction
The U.S. Congress passed the Patient Protection and Affordable Care Act in 2010 with the aim of improving the well-being of American residents covered by health insurance. According to Chu et al. (688), the Act also aimed to limit health care expenses. At the basic level, the act was approved with the intention of ensuring the majority of Americans are able to “maintain the least essential coverage on health insurance” (Chu et al. 688). For those employees excluded from health insurance either directly by their employers or government program beneficiaries, they were eligible to obtain insurance through private companies. Those who failed to comply with this law were required to pay a casual tax penalty. More specifically, they are expected to make payments in the form of shared responsibility – the amount is directed to the Internal Revenue Service.
The Act was also introduced with the aim of expanding Medicaid in an effort to accommodate elderly people, children and needy families. In fact, the scope of Medicaid witnessed a rapid expansion following the enactment of the Act – it incorporated the individuals whose income was “categorized under the poverty line” (Chu et al. 688). However, this act was not received well by some factions of the society. A total of 26 states, together with two plaintiffs and the National Federal Business (NFIB) introduced a lawsuit requiring detailed examination of several provisions put forth by the Act.
Case Brief
The lawsuit passed through several courts, including the Eleventh Circuit Court of appeal, before reaching the Supreme Court. The Eleventh Circuit, in its ruling, made several clarifications while also affirming some decisions made by the lower court. For instance, the Court agreed with the ruling that the Medicaid expansion was “not unconstitutionally coercive and that the individual mandate was unconstitutional” (Banister 123). The court also held that the individual mandate could also be split without necessarily invalidating the entire Act.
When the case reached the Supreme Court, it ended up overturning the Judgment previously rendered by the Eleventh Circuit. The Supreme Court made a ruling on five key issues – one for all the parties involved, two for NFIB and two other findings in support of the Affordable Care Act (ACA). In their ruling the judges voted on the basis of their ideological reputations (Banister 124). The majority ruling was written by Chief Justice John Roberts. Others who joined him on key issues included Ruth Bader Ginsburg, Stephen Breye, Sonia Sotomayor and Elena Kagan. Justices Antonin Scalia, Anthony Kennedy, Samuel Alito, and Clarence Thomas wrote the dissenting opinion. The Court was required to make a ruling on several issues surrounding the ACA. Firstly, the Supreme Court was called upon to make a determination as to whether Congress had the power to compel individuals to purchase health insurance. Secondly, the Court needed to establish whether the Medicaid expansion requirement was constitutional. Lastly, the Supreme Court needed to make a ruling as to whether individual mandates could be split off from the rest of the law.
The Supreme Court, in a 5-4 decision, overturned the ruling previously made by the Eleventh Circuit. In its ruling, the Court concluded that the individual mandate was constitutional “under the constitution’s Taxing and Spending Clause” (Banister 125). Similarly, the Court upheld the expansion of Medicaid but voted to remove the provision supporting the withholding of federal Medicaid funds for those states that failed to expand the program.
In a detailed ruling, the Supreme Court held that the ACA’s individual mandate was within Congress’ own jurisdiction as per Article 1. They have powers to not only lay and collect taxes but also make a declaration regarding its legality. This explains why they arrived at a conclusion that the penalty is a form of tax. Chief Justice John Roberts further wrote “The court today holds that our Constitution protects us from federal regulation under the Commerce Clause so long as we abstain from the regulated activity” (Banister 124). However, the chief justice added that the constitution does not offer the same protection with respect to taxes. It is clear that the application of the rule of law with respect to NFIB was that individual mandate provision in the act is actually a tax and, as such, does not infringe the constitution.
The Court also found that the decision of the government to discontinue Medicaid funding to those states that failed to expand the program is nothing but a form of coercion. According to the Court, the law was followed strictly in transforming the Medicaid program into an extensive national plan whose mandate was to offer universal health coverage (Banister 122). This means that the Medicaid expansion was not mandatory – the states were at liberty to choose whether or not to expand the program.
The four remaining justices, Antonin Scalia, Anthony Kennedy, Samuel Alito, and Clarence Thomas wrote the dissenting opinion. According to them, the individual mandate was an illegitimate regulation initiated by interstate commerce – its main intention was to coerce people to engage in a specific transaction (Banister 122). The justices maintained that the fact that everyone consumes food does not mean that the government has the obligation or the power to decide when and what the people will buy (Banister 122). This is the same thing that the Act intends to achieve with regard to the purchase of health care. They also wrote in their dissenting judgment that the individual mandate was more of an abuse of federal power because the Commerce Clause has never been used to force entry into commerce (Banister 123). Their overriding argument, according to Banister was that the individual mandate was an illegitimate exercise of the power to tax because “the statute describes the fine as a penalty rather than a tax” (123). As per the justices, the Affordable Care Act needed to be overturned because it could not accomplish its objectives without the individual mandate.
Conclusion
Overall, the National Federation of Independent Business v. Sebelius was a landmark ruling because its main intention was to challenge the constitutionality of the Affordable Care Act. A major ruling in this case was that the individual mandate provision in this act was a tax and, as such, did not violate the constitution. However, the main reason why the Supreme Court upheld the Patient Protection and Affordable Care Act was to solve the problem of lack of health insurance. The court was aware that a large number of people did not have any form of health insurance despite being actively involved in the healthcare market. Additionally, most of the people enjoy health care services without any form of payment. The Court concluded that anyone who failed to abide by the regulations as set out in the individual mandate was required to pay a tax penalty.
Works Cited
Banister, John. “The Dissociations of John Roberts: National Federation of Independent Business V. Sebelius and the Discontents of Judicial Supremacy.” Argumentation and Advocacy, vol. 57, no. 2, Informa UK Limited, 2021, pp. 123–39. Web.
Chu, Quyen D., et al. “Positive Impact of the Patient Protection and Affordable Care Act Medicaid Expansion on Louisiana Women with Breast Cancer.” Cancer, vol. 127, no. 5, Wiley, 2020, pp. 688–99. Web.