Florida Ex Rel. Bondi v. United States Department of Health & Human Services
780 F. Supp. 2d 1256
| N.D. Fla. | 2011Background
- Case filed in the U.S. District Court for the Northern District of Florida challenging the Patient Protection and Affordable Care Act following its March 23, 2010 enactment; plaintiffs include Florida and other states, private individuals, and NFIB; defendants are HHS, Treasury, and Labor secretaries; proceedings involved cross-motions for summary judgment on two counts (Count I—individual mandate; Count IV—Medicaid expansion); court held oral argument and considered extensive briefing and amicus briefs; court addressed constitutional questions about federalism, the Commerce Clause, and the Spending Clause; court resolved the Medicaid issue before addressing the individual mandate and applied standard summary-judgment review; court concluded the case presents questions of law with disputed facts but that the dispositive issues are constitutional interpretations; court ultimately found the mandate unconstitutional and non-severable from the Act, resulting in the Act being declared void.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Medicaid expansion violates the Spending and federalism constraints. | State plaintiffs contend expansion imposes coercive, unfunded burdens. | Defendants argue Medicaid participation remains voluntary and within spending powers. | Summary judgment for defendants on Count IV; Medicaid expansion unconstitutional as applied. |
| Whether the individual mandate is within Congress's Commerce Clause power. | Plaintiffs assert the mandate exceeds the Commerce Clause and is unprecedented. | Defendants argue the mandate is a valid exercise of Commerce Clause or, alternatively, Necessary and Proper Clause. | The mandate exceeds the Commerce Clause and cannot be sustained by the Necessary and Proper Clause; granting judgment for plaintiffs on Count I. |
| Whether the individual mandate can be severed from the Act if unconstitutional. | Severability should preserve remaining provisions if feasible. | Mandate is essential to the Act; severability should be possible if remaining provisions function independently. | Non-severable; the mandate is essential and the whole Act must be void. |
Key Cases Cited
- Gibbons v. Ogden, 22 U.S. (9 Wheat.) 1 (1824) (definition of commerce; early federal power over interstate regulation)
- McCulloch v. Maryland, 17 U.S. (4 Wheat.) 316 (1819) (enumerated powers; federal power limited to those granted)
- Kidd v. Pearson, 128 U.S. 1 (1888) (commerce power limited; historical restraint on federal reach)
- Wickard v. Filburn, 317 U.S. 111 (1942) (aggregation principle; substantial effect on interstate commerce)
- United States v. Lopez, 514 U.S. 549 (1995) (three categories of activity; limits on Commerce Clause power)
- United States v. Morrison, 529 U.S. 598 (2000) (limits on regulating noneconomic activity under Commerce Clause)
- Gonzales v. Raich, 545 U.S. 1 (2005) (local activity with substantial effect on interstate commerce; economic regulation)
- Printz v. United States, 521 U.S. 898 (1997) (limitations on Necessary and Proper Clause power; federalism concerns)