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Florida v. Department of Health and Human Services

Summarized by: 

Date Filed: March 28, 2012
Case #: 11-400
Court Below: 648 F.3d 1235 (11th Cir. 2011)
Full Text Opinion: http://www.uscourts.gov/uscourts/courts/ca11/201111021.pdf

Constitutional Law: (1) Whether Congress may make federal Medicaid funding contingent upon States providing expanded health care in order to coerce States into accepting conditions that Congress would be otherwise unable to impose directly; and (2) Whether the individual mandate that requires Americans to purchase health insurance, if deemed unconstitutional, may be severed from the rest of the Patient Protection and Affordable Care Act.

(Question two is consolidated with Florida National Federation of Independent Business v. Sebelius (11-393) for ninety minutes of argument.)

Congress passed the Patient Protection and Affordable Care Act (the Act) in an effort to achieve near universal health insurance coverage for Americans. Twenty-six states along with a group of private individuals (Petitioners) challenged two aspects of the Act. The first was the individual mandate provision (mandate) that required nearly all Americans to purchase health insurance. The second was the Act’s expansion of Medicaid to require States seeking federal reimbursement to cover everyone under age 65 with an income up to 133% of the poverty level.

The District Court rejected the Petitioners’ challenge to the Medicaid expansion and the Court of Appeals for the Eleventh Circuit affirmed, holding that Petitioners had failed to establish coercion. As to severability, the District Court held that the individual mandate could not be severed from the Act and the Eleventh Circuit held that the mandate was entirely severable.

Petitioners argue that the Act would not function as congress intended if the individual mandate were to be severed since the Act’s insurance regulations are part of an intricate scheme that cannot operate independently of the mandate, and warn of separation-of-powers issues that arise when the Court severs parts of an act Congress intended to be whole. Petitioners also argue that the Act’s amendments to Medicaid are unconstitutional since Congress is prohibited from using its spending power to coerce States under New York v. United States’ coercion doctrine.