Land of Lincoln Mutual Health Insurance Co. v. United States

Questions presented

SCOTUS records, cert granted 24 Jun 2019

This case involves the "risk corridors" program established by the Patient Protection and Affordable Care Act ("ACA''), 42 U.S.C. § 18062, which mandates that for the first three years of the ACA, the Government "shall pay" mathematically determined amounts to health insurers based on a statutory formula in order to induce them to participate in health insurance exchanges and to reduce the premiums they would otherwise charge. In this case, the Federal Circuit held on the basis of legislative history that the Government's obligation to make risk corridors payments was extinguished by appropriations riders temporarily foreclosing certain sources of funds for the risk corridors program. The riders were included in spending bills enacted several years after the ACA was adopted - and after Petitioner had already performed its part of the bargain under the risk corridors program. The Question Presented is: Whether a temporary cap on appropriations availability from certain specified funding sources may be construed, based on its legislative history, to abrogate retroactively the Government's payment obligations under a money-mandating statute, for parties that have already performed their part of the bargain under the statute.

Opinion summary

Etalia.ai summary of the majority opinion

The case involved Land of Lincoln Mutual Health Insurance Co., which participated in the Affordable Care Act's (ACA) risk corridors program, designed to mitigate financial losses for insurers during the initial years of ACA implementation. The company claimed it was owed payments by the federal government under this program but had not received them due to Congress’s decision to limit funding through appropriations riders. The Supreme Court ruled that despite these limitations, the government still had a statutory obligation to pay insurers as per their original agreement under Section 1342 of the ACA. This ruling emphasized that legislative intent and commitments made by statutes cannot be undone solely through subsequent appropriation restrictions without explicitly repealing or amending those obligations.