History
  • No items yet
midpage
California v. Texas
593 U.S. 659
SCOTUS
2021
Read the full case

Background

  • 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)
Read the full case

Case Details

Case Name: California v. Texas
Court Name: Supreme Court of the United States
Date Published: Jun 17, 2021
Citation: 593 U.S. 659
Docket Number: 19-840
Court Abbreviation: SCOTUS