State of Ohio v. United States, 849 F.3d 313

Ohio and several political subdivisions and public universities paid approximately $6.1 million (2014 benefit year) into the ACA’s Transitional Reinsurance Program and sued HHS seeking refunds and a declaration that the Program does not apply to state employers.
The Transitional Reinsurance Program (42 U.S.C. § 18061) requires "health insurance issuers" and "third party administrators on behalf of group health plans" to make per-enrollee contributions for 2014–2016; HHS administered Ohio’s program.
The ACA adopts the Public Health Service Act (PHSA) definition of "group health plan," which in turn references ERISA’s definition of "employee welfare benefit plan," and ERISA recognizes "governmental plans."
Ohio argued (1) the Program’s statutory definition does not plainly cover state-provided plans (invoking the plain-statement rule and ERISA textual limits), and (2) applying the Program to the State violates the Tenth Amendment through anti-commandeering and intergovernmental tax-immunity doctrines.
The district court dismissed Ohio’s claims and denied Ohio summary judgment; the Sixth Circuit affirmed, holding that the statutory definitions encompass state group health plans and that application to Ohio does not violate federalism principles.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether "group health plan" under the Transitional Reinsurance Program includes state and local government plans	Ohio: statutory definitions and ERISA text do not plainly reach state plans; invoke plain-statement rule	U.S.: ACA adopts PHSA/ERISA definitions that plainly include governmental plans; cross-references suffice	Held: term includes state plans; cross-references to PHSA and ERISA show Congress intended inclusion
Whether the Program violates the Tenth Amendment via anti-commandeering	Ohio: requiring states to collect/pay is commandeering state sovereignty	U.S.: Program is a generally applicable regulatory obligation, not commandeering implementation of a federal program	Held: No commandeering; Congress may regulate state activities like private conduct (Garcia line)
Whether the Program violates intergovernmental tax immunity	Ohio: federal tax/charge on states infringes immunity and sovereignty	U.S.: immunity today protects only discriminatory taxation; Program is nondiscriminatory	Held: No violation; Program is nondiscriminatory and permissible under modern doctrine
Whether Ohio is entitled to refund or declaratory relief based on arbitrary or capricious agency interpretation	Ohio: HHS misinterpreted "group health plans" and applied rule unlawfully	U.S.: interpretation consistent with statutory cross-references and regulatory scheme	Held: APA challenge fails; statutory text and structure support HHS interpretation

King v. Burwell, 135 S. Ct. 2480 (2015) (context on ACA’s structure and nationwide coverage provisions)
Garcia v. San Antonio Metro. Transit Auth., 469 U.S. 528 (1985) (permits Congress to regulate state employers like private employers under Commerce Clause)
Printz v. United States, 521 U.S. 898 (1997) (illustrates commandeering doctrine where federal law required state officers to execute federal tasks)
New York v. United States, 505 U.S. 144 (1992) (commandeering precedent invalidating federal compulsion of state legislative action)
New York v. United States, 326 U.S. 572 (1946) (origin of intergovernmental tax-immunity concept)
Massachusetts v. United States, 435 U.S. 444 (1978) (discusses limits and political-process remedy for federal taxation of states)
Mich. v. United States, 40 F.3d 817 (6th Cir. 1994) (applies plain-statement rule in tax context; discusses erosion of broad state tax immunity)
Travis v. Reno, 163 F.3d 1000 (7th Cir. 1998) (explains modern nondiscrimination focus of intergovernmental immunity doctrine)
Sebelius v. Auburn Reg'l Med. Ctr., 133 S. Ct. 817 (2013) (noting that Congress need not use "magic words" and considering statutory context in ACA interpretation)