California v. Texas
593 U.S. 659
SCOTUS2021Background
- The Affordable Care Act (ACA) originally required most individuals to maintain "minimum essential coverage" and imposed a penalty for noncompliance (26 U.S.C. §5000A); the Tax Cuts and Jobs Act of 2017 set that penalty to $0 effective 2019.
- Texas (and 17 other States) and two individuals sued federal officials seeking a declaration that §5000A(a) (the individual mandate) is unconstitutional and that the rest of the ACA is inseverable and therefore invalid.
- The District Court found the individual plaintiffs had standing, held §5000A(a) unconstitutional and nonseverable, and enjoined the ACA; the Fifth Circuit affirmed standing and unconstitutionality but remanded on severability.
- The United States (federal defendants) agreed the mandate is unconstitutional; California and other States intervened to defend the ACA; the Supreme Court granted certiorari.
- The Supreme Court disposed of the case on standing: it held neither the individual plaintiffs nor the state plaintiffs demonstrated an injury fairly traceable to enforcement of the challenged statutory provision, and thus lacked Article III standing; the Court remanded with instructions to dismiss.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Standing of individual plaintiffs to challenge §5000A(a) | Hurley & Nantz: pocketbook injury from buying insurance required by the statute | Government: mandate now unenforceable (penalty $0); no government action causing injury | No standing — injury not fairly traceable or redressable because §5000A(a) lacks enforcement; declaratory relief alone insufficient |
| Standing of States for increased costs from more Medicaid/CHIP enrollment | States: mandate caused more enrollments and higher state costs | Government: any enrollment link is speculative, and mandate without penalty provides no enforcement incentive | No standing — claims rest on speculative third‑party choices; evidence insufficient to show predictable reaction |
| Standing of States for direct administrative/reporting costs (§6055/6056, employer mandates, adult‑child coverage) | States: reporting, employer mandates, and coverage obligations impose real costs tied to ACA | Government: those costs arise from other, independently enforceable ACA provisions, not §5000A(a) | No standing — alleged pocketbook injuries traceable to other provisions, not enforcement of §5000A(a) |
| Severability of §5000A(a) from the rest of the ACA | Plaintiffs: mandate is inseverable; if mandate invalid, many ACA provisions fall | Intervenors/Govt: mandate is severable from many ACA provisions | Not reached — Court resolved the case on standing and did not decide severability or the mandate's constitutionality |
Key Cases Cited
- DaimlerChrysler Corp. v. Cuno, 547 U.S. 332 (standing requires injury fairly traceable to defendant)
- Allen v. Wright, 468 U.S. 737 (traceability requirement for standing)
- Lujan v. Defenders of Wildlife, 504 U.S. 555 (injury in fact and traceability principles)
- MedImmune, Inc. v. Genentech, Inc., 549 U.S. 118 (declaratory judgments must satisfy Article III)
- Whitmore v. Arkansas, 495 U.S. 149 (pocketbook injury can satisfy injury in fact)
- Babbitt v. United Farm Workers Nat. Union, 442 U.S. 289 (standing requires injury from statute's enforcement)
- Susan B. Anthony List v. Driehaus, 573 U.S. 149 (threatened enforcement must be substantial for standing)
- Clapper v. Amnesty Int'l USA, 568 U.S. 398 (speculative chains defeat standing)
- National Fed'n of Indep. Business v. Sebelius, 567 U.S. 519 (ACA precedent addressing the individual mandate and severability issues)
- King v. Burwell, 576 U.S. 473 (statutory interpretation and ACA structure)
- Steel Co. v. Citizens for a Better Environment, 523 U.S. 83 (jurisdictional limits and merits distinction)
- Massachusetts v. Mellon, 262 U.S. 447 (injunctive relief operates against officials; jurisdictional limitations on preventive relief)
