California v. Texas
Headline: Court dismisses challenge to ACA’s zero-dollar individual mandate, ruling plaintiffs lack standing and blocking this route for striking down the law while leaving most ACA rules in place for now.
Holding: The Court held that the individual plaintiffs and the States lacked Article III standing to challenge the ACA’s minimum essential coverage requirement because they did not show injuries fairly traceable to enforcement of that provision.
- Prevents this federal court challenge, making it harder to strike down ACA over the zeroed-out mandate.
- Leaves most of the Affordable Care Act in place for now.
- Limits who can sue in federal court over laws the Government cannot enforce.
Summary
Background
A group of States led by Texas and two individuals sued to overturn the Affordable Care Act’s rule that says people must have “minimum essential” health insurance. When Congress cut the penalty for not having insurance to $0 in 2017, the IRS stopped collecting or requiring related reporting. The plaintiffs asked courts to declare the coverage requirement unconstitutional and to strike down the rest of the law as inseparable from that requirement.
Reasoning
The Court took up the case but decided only the question of who may bring the suit (standing). It explained that federal courts can hear only real disputes where a plaintiff shows a concrete injury caused by the defendant’s unlawful action and that a court’s order could fix the harm. The two individuals’ out-of-pocket insurance costs were not shown to result from any current or threatened government enforcement, because the penalty is $0 and the IRS no longer enforces the mandate. The States’ claims—that the mandate increased enrollment in state programs or forced extra administrative work—either relied on speculation or came from other independent parts of the law.
Real world impact
Because the Court found no traceable injury tied to enforcement of the specific statutory provision attacked, it held the plaintiffs lacked Article III standing and sent the case back with instructions to dismiss. The ruling resolves this procedural obstacle without deciding whether the law’s coverage requirement is constitutional on the merits.
Dissents or concurrances
Justice Thomas agreed with the standing result but added separate views. Justice Alito (joined by Gorsuch) dissented, arguing the States did show real costs and that the mandate is now unconstitutional and inseverable, a view the majority did not adopt.
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