Peterson v. United States
774 F. Supp. 2d 418
D.N.H.2011Background
- Peterson, a Medicare recipient from New Hampshire, sues the United States and federal officials challenging the ACA.
- He alleges the ACA's individual health insurance mandate violates the Takings, Commerce, Ninth and Tenth Amendments, and presentment/oath clauses, and challenges the manner of passage.
- Defendants move to dismiss for lack of subject-matter jurisdiction, arguing Peterson lacks standing since Medicare already satisfies the mandate and injuries are speculative.
- Peterson contends Medicare and premium increases render him injured and that the Act’s passage violated constitutional procedures.
- The court grants the motion, concluding Peterson has no standing to challenge the mandate or the passage, and that the presentment/oath claims fail on the merits or are nonjusticiable.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Standing to challenge the mandate | Peterson asserts injury from the mandate despite Medicare coverage. | Medicare already satisfies the mandate; no actionable injury. | No standing; lack of injury traceable to mandate; claims dismissed. |
| Standing to challenge the Act's passage | Act's passage affected his premiums and benefits; injury is concrete. | Increases speculative and injuries not redressable; third-party action. | No standing; speculative injuries and lack of redressability; claims dismissed. |
| Presentment Clause and Presidential Oath of Office claims | Different versions passed via reconciliation and oath violation. | No single-subject requirement; reconciliation bills passed appropriately; oath challenges nonjusticiable. | Dismissed for lack of standing; merits would also fail if reached. |
Key Cases Cited
- Lujan v. Defenders of Wildlife, 504 U.S. 555 (U.S. 1992) (standing requires concrete injury and redressability)
- Warth v. Seldin, 422 U.S. 490 (U.S. 1975) (construe in favor of plaintiffs, but requires standing)
- Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375 (U.S. 1994) (jurisdictional principles and dismissal for lack of jurisdiction)
- Steel Co. v. Citizens for a Better Env't, 523 U.S. 83 (U.S. 1998) (jurisdictional issues; power to declare law)
- Davis v. Fed. Election Comm'n, 554 U.S. 724 (U.S. 2008) (standing for each claim and form of relief)
- Evans v. Thompson, 518 F.3d 1 (1st Cir. 2008) (binding Supreme Court precedent governs standing limitations)
- Nulankeyutmonen Nkihtaqmikon v. Impson, 503 F.3d 18 (1st Cir. 2007) (standing standards; procedural injuries contextual)
- Burton v. Central Interstate Low-Level Radioactive Waste Compact Comm'n, 23 F.3d 208 (8th Cir. 1994) (standing where alleged injury not causally linked to defendant conduct)
- Glanton ex rel. ALCOA Prescription Drug Plan v. AdvancePCS Inc., 465 F.3d 1123 (9th Cir. 2006) (redressability requires concrete link to relief)