District Court

District Court

Florida v. Department of Health and Human Services (N.D. Fla.)

The Northern District of Florida held that (1) the ACA’s Medicaid provisions did not exceed Congress’s power under the Spending Clause, (2) Congress lacked authorization under the Commerce Clause and the Necessary and Proper Clause to enact the individual mandate, and (3) the individual mandate was not severable from the remainder of the ACA, meaning that the entire ACA is invalid.


Liberty University, et al. v. Geithner, et al. (W.D. Va.)

The Western District of Virginia held that (1) the Anti-Injunction Act did not bar judicial challenges to penalties imposed for violations of the employer and individual mandates, (2) Congress acted within the scope of its Commerce Clause power when enacting the individual mandate, (3) the ACA, as applied to religious groups and individuals, did not violate the Establishment Clause, Free Exercise Clause, Equal Protection Clause, or Free Speech Clause.


Mead, et al. v. Holder, et al. (D.D.C.)

The District of D.C. ruled that (1) the individual mandate was within Congress’s powers under the Commerce Clause and the Necessary and Proper Clause, and (2) the ACA did not place a substantial burden on the exercise of religion under the Religious Freedom Restoration Act.

  • Memorandum Opinion 
    (February 22, 2011)    
  • Memorandum in Support of the Defendants’ Motion to Dismiss 
    (August 20, 2010)    
  • Reply in Support of Defendants’ Motion to Dismiss 
    (September 24, 2010)   
  • Plaintiffs’ Memorandum in of Points and Authorities in Response to Defendants’ Motion to Dismiss 
    (September 10, 2010)  

Thomas More Law Center, et al. v. Obama, et al. (E.D. Mich.)

The Eastern District of Michigan ruled that (1) the Anti-Injunction Act did not bar pre-enforcement judicial review of the ACA; (2) Congress had the power under the Commerce Clause to enact the individual mandate; (3) the provision of the ACA imposing a penalty for failure to buy health insurance was not an improperly apportioned direct tax in violation of the General Welfare Clause.

  • Order Denying Plaintiffs’ Motion for Injunction and Dismissing Plaintiffs’ First and Second Claims for Relief 
    (October 7, 2010)    
  • Defendants’ Surreply to Plaintiffs’ Motion for Preliminary Injunction and Brief in Support 
    (July 14, 2010)   
  • Plaintiffs’ Reply Brief in Support of Motion for a Preliminary Injunction 
    (June 3, 2010)   
  • Defendants’ Response to Plaintiffs’ Motion for Preliminary Injunction and Brief in Support 
    (May 11, 2010)   
  • Plaintiffs’ Motion for a Preliminary Injunction & Brief in Support 
    (April 6, 2010)    
  • Complaint
    (March 23, 2010)

Virginia v. Sebelius (E.D. Va.)

The Eastern District of Virginia concluded that (1) the individual mandate exceeded the scope of Congress’s authority under the Commerce Clause, (2) the ACA imposed a penalty, rather than a tax, for violation of the individual mandate, and thus could not be justified as an exercise of Congressional power under Taxing and Spending Clause, and (3) the individual mandate was not severable from the remainder of the ACA.

  • Memorandum Opinion 
    (December 13, 2010)      
  • Reply Memorandum in Support of Plaintiff’s Motion for Summary Judgment 
    (October 4, 2010)    
  • Reply Memorandum in Support of Defendant’s Motion for Summary Judgment 
    (October 4, 2010)   
  • Plaintiff’s Memorandum in Opposition to the Secretary’s Motion for Summary Judgment
    (September 23, 2010)   
  • Memorandum in Opposition to Plaintiff’s Motion for Summary Judgment 
    (September 23, 2010)   
  • Plaintiff’s Memorandum in Support of Motion for Summary Judgment 
    (September 3, 2010)   
  • Memorandum in Support of Defendants’ Motion for Summary Judgment 
    (September 3, 2010)   
  • Complaint for Declaratory and Injunctive Relief
    (March 23, 2010)
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