Liberty University, Inc. v. Geithner, 753 F. Supp. 2d 611

Plaintiffs challenge the ACA as unconstitutional on multiple grounds; Defendants move to dismiss for lack of jurisdiction and failure to state a claim.
The court addresses challenges to the employer and individual coverage provisions (42 U.S.C. § 1513, § 1501) and exemptions for religious conscience and health care sharing ministries.
The act imposes penalties for noncompliance, to be assessed and collected similarly to taxes, but the court holds penalties are regulatory, not taxes, for Anti-Injunction Act purposes.
Plaintiffs seek relief including declarations of invalidity and injunctions against enforcement; standing and ripeness are central to jurisdiction.
This is a facial challenge; the court analyzes standing, ripeness, and constitutional authority under the Commerce Clause, with related Establishment, Free Exercise, RFRA, and Equal Protection considerations.
The court ultimately grants Defendants’ motion to dismiss on jurisdictional and merits grounds.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Do plaintiffs have standing to sue now?	Liberty, Waddell, Merrill alleged imminent costs and compliance pressures.	Injury in fact must be imminent and concrete; future uncertainties defeat standing.	Yes; standing found for standing as to present/near-term due to anticipated costs.
Is the case ripe for adjudication?	Pre-enforcement burden and imminent compliance costs render it ripe.	Ripeness requires concrete controversy; long lead time before 2014 undermines ripeness.	Not premature; facial challenge deemed ripe because of immediate regulatory effects.
Does Congress have authority under the Commerce Clause to enact the individual and employer coverage provisions?	Individual failure to purchase insurance is inactivity and not commercial; cannot affect interstate commerce.	Decisions to pay for health care are economic activities with substantial effects on interstate health care market.	Yes; both provisions comply with Commerce Clause; counts 1 and related theories dismissed.
Is the Anti-Injunction Act a bar to the suit?	Penalties are taxes; thus suit barred under § 7421(a).	Penalties are regulatory; not taxes; AIA does not bar this challenge.	AIA does not deprive jurisdiction; penalties are regulatory penalties, not taxes for AIA purposes.

Massachusetts v. EPA, 549 U.S. 497 (2007) (standing and jurisdiction principles for Article III)
Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992) (standing requires injury, causation, redressability)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (pleading standards; plausibility over mere conclusory allegations)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (plausibility standard; reject mere legal conclusions)
Raich v. United States, 545 U.S. 1 (2005) (regulation of intrastate activity with substantial interstate effects)
Wickard v. Filburn, 317 U.S. 111 (1942) (expanded Commerce Clause to local economic activity)
United States v. Lopez, 514 U.S. 549 (1995) (limits on non-economic activities under Commerce Clause)
United States v. Morrison, 529 U.S. 598 (2000) (limits on noneconomic conduct under Commerce Clause)
Cutter v. Wilkinson, 544 U.S. 709 (2005) (accommodations for religious exercise within Establishment/Free Exercise)
New York v. United States, 505 U.S. 144 (1992) (federalism and state exchanges; Congress power to offer choice)
South-Eastern Underwriters Ass'n, 322 U.S. 533 (1944) (insurance regulation within Commerce Clause)
Leckie Smokeless Coal Co. v. United States, 99 F.3d 573 (4th Cir. 1996) (Leckie test for Anti-Injunction Act applicability)