Term: 2020
Docket: 19-840
California v. Texas
- Pro
19-840 CALIFORNIA V. TEXAS DECISION BELOW: 945 F.3d 355 CONSOLIDATED WITH 19-1019 FOR ONE HOUR ORAL ARGUMENT. CERT. GRANTED 3/2/2020 QUESTION PRESENTED: As part of the Patient Protection and Affordable Care Act (ACA), Congress adopted 26 U.S.C. § 5000A. Section 5000A provided that "applicable individual[s] shall" ensure that they are "covered under minimum essential coverage," 26 U.S.C. § 5000A(a); required any "taxpayer" who did not obtain such coverage to make a "[s]hared responsibility payment," id.§ 5000A(b); and set the amount of that payment, id. § 5000A(c). In National Federation of Independent Business v. Sebelius, 567 U.S. 519, 574 (2012), this Court held that Congress lacked the power to impose a stand-alone command to purchase health insurance but upheld Section 5000A as a whole as an exercise of Congress's taxing power, concluding that it affords individuals a "lawful choice" between buying health insurance or paying a tax in the amount specified in Section 5000A(c). In 2017, Congress set that amount at zero but retained the remaining provisions of the ACA. The questions presented are: 1. Whether the individual and state plaintiffs in this case have established Article III standing to challenge the minimum coverage provision in Section 5000A(a). 2. Whether reducing the amount specified in Section 5000A(c) to zero rendered the minimum coverage provision unconstitutional. 3. If so, whether the minimum coverage provision is severable from the rest of the ACA. LOWER COURT CASE NUMBER: 19-10011
In the case of California v. Texas, 2020, the Supreme Court was asked to rule on whether the individual mandate in the Affordable Care Act (ACA), also known as Obamacare, became unconstitutional after Congress reduced its penalty to zero dollars in 2017 and if it could be severed from the rest of ACA. The plaintiffs argued that without a financial penalty, there is no tax for not having health insurance which makes it unconstitutional based on previous rulings by SCOTUS. They further contended that if this provision is deemed unconstitutional then all other provisions should fall with it because they are interconnected. However, in a 7-2 decision announced June 17th, 2021; Justices Breyer wrote an opinion joined by Chief Justice Roberts and Justices Thomas, Sotomayor , Kagan , Kavanaugh and Barrett stating that neither states nor individuals can show harm from being forced to pay $0 so they do not have standing or legal right to sue over constitutionality of mandate itself . Therefore court did not address severability issue.
In the dissenting opinion for California v. Texas, Justice Alito, joined by Justice Gorsuch, argued that the individual mandate of the Affordable Care Act (ACA) is unconstitutional and not severable from other provisions of ACA. They contended that when Congress reduced the penalty for non-compliance to zero in 2017, it effectively rendered this provision a command rather than a tax - thus exceeding congressional authority under Article I's Taxing Clause. The justices further asserted that because this "command" was integral to ACA’s structure as originally enacted in 2010, its unconstitutionality should bring down related provisions or possibly even entire law with it. They criticized their colleagues' decision as an instance of judicial activism and expressed concern about potential implications on separation-of-powers principles.
