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Rabu, 20 Juni 2018

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National Independent Business Federation v. Sebelius, 567 US 519 (2012), is an important decision of the United States Supreme Court in which the Court upholds the power of Congress to enforce most provisions of the Patient Protection and Affordable Care Act (ACA), commonly referred to Obamacare and the Healthcare and Education Act (HCERA), including the requirements for most Americans to have health insurance by 2014. This story represents a series of major changes to the American health care system that has been a highly controversial debate subject, which mostly divided into political party lines.

The Supreme Court, in an opinion written by Chief Justice John Roberts, is supported by a vote of 5 to 4 mandates of individuals to purchase health insurance as a constitutional exercise of Congressional tax power. The majority of judges, including Supreme Court Justice Roberts, agree that the individual's mandate is not the proper use of the terms of the treaty trade or the necessary powers and clause rights, although they do not join in one opinion. The majority of judges also agree that other provisions that are opposed from the Act, a significant Medicaid expansion, are not valid exercises from the power of Congress spending as it will force countries to accept the expansion or risk of losing existing Medicaid funds.


Video National Federation of Independent Business v. Sebelius



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In March 2010, President Barack Obama signed the Patient Protection and Affordable Care Act into law. A number of parties sued, including the National Independent Business Federation, claimed that sweeping reform laws were unconstitutional for various reasons. The Supreme Court granted certiorari to three cases, for a total of 5 ½ hours of oral argument: National Federation of Independent Business v. Sebelius (which consolidates parts of Florida v. Department of Health and Human Services ) on the issue of constitutionality of individual mandates and the severity of unconstitutional provisions, Dept. Health and Human Services v. Florida on the matter of whether the review is prohibited by the Anti-Injury Act, and Florida v. Department of Health and Human Services on the issue of constitutionality of Medicaid expansion.

District Court Process

The state of Florida filed a lawsuit against the US Department of Health and Human Services, challenging the constitutionality of the law. On 31 January 2011, Judge Roger Vinson ruled that health insurance mandatory "mandate of the individual" - the provision of Internal Revenue Code section 5000A which imposes a "joint responsibility responsibility" on almost all Americans who fail to purchase health insurance - is outside the power of Congress. Vinson also stated that the mandate can not be decided from other parts of the Affordable Care Act and has abolished the entire Act.

The appeal of the Eleventh Circuit

The Department of Health and Human Services appealed to the 11th Circuit Court of Appeals. The three-judge panel issued a 2-1 verdict that confirmed Judge Vinson's findings in part and partially reversed. The Court affirmed that the District Court is of the opinion that the individual's mandate is unconstitutional, but, contrary to the views of the District Courts, he argues that the individual's mandate may be terminated, leaving the remaining legal remains intact. The government decided not to seek a review of the full Circuit and instead petitioned the United States Supreme Court to review the decision of the Eleventh Circuit.

Related case

Other federal courts heard cases related to the Affordable Care Act that were not reviewed directly by the Supreme Court, but caused differences in the constitutionality of the law. Two federal judges appointed by President Bill Clinton uphold the mandate of the individual in 2010. Judge Jeffrey Sutton, member of the Sixth Circuit Court of Appeal appointed by George W. Bush, is the first judge appointed by the Republicans to decide that the law is constitutional in June 2011, as part of a separate three-judge panel that upholds the constitutionality of the law.

Maps National Federation of Independent Business v. Sebelius



Direction and oral arguments

On November 14, 2011, the Supreme Court granted certiorari to the part of the three cross-references of the Eleventh Circuit opinion: one by the state ( Florida v. Department of Health and Human Svcs of the USA. ), one by the federal government (< i> Department of Health and Human Svcs AS v. Florida ); and one by the National Federation of Independent Businesses ( Nat'l Fed. from Independent Buses v. Sebelius ).

Verbal arguments

The Court announced in December 2011 that they would hear about six hours of verbal argument over three days, from Monday, March 26 to Wednesday, March 28, 2012, covering the various aspects questioned by the major parties involved in this. and other related cases of ACA.

The court first hears the argument about whether the Anti-Dysfunction Act, which limits it accordingly "for the purpose of withholding any assessment or collection of any tax", forbids the decision before the ACA fully takes effect in 2014. Since both governments, represented by General Attorney Donald Verrilli, or state, represented that day by Gregory G. Katsas of the Jones Day law firm, willing to defend the position (which has been accepted by three of the twelve appellate court judges who heard the cases) The court appointed Robert Long of the Covington & amp; Burling as an amicus curiae to maintain that position.

On the second day, the court heard the argument about whether the component of the "individual" mandate of the ACA falls under the constitutional powers of the Congress. The countries (Florida et al.) Were represented during the trial by former Bush administration Public Lawyer Paul Clement while the government was represented by current General Attorney Donald Verrilli.

On the third morning, the Court considered bankruptcy issues - whether the Affordable Care Act could survive if the Court dropped the individual's mandate. Paul Clement, Deputy Attorney General Edwin Kneedler, and the Court appoints amicus curiae H. Bartow Farr, III of Farr & amp; Taranto put forward their various positions before the Court.

On the third afternoon, the Court considered whether the expansion of the Medicaid that the Affordable Care Act was instituted was coercive. Both Paul Clement and Donald Verilli once again argued before the Court. Justice Roberts extended the deadline for both parties for 15 minutes during the argument.

Solicitor General Verrilli's performance during the hearing was heavily criticized by analysts.

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Court Opinion

The Supreme Court is divided into many problems. Judge Agung Roberts wrote the Court's view of the Anti-Violation Act and the tax authority of Congress.

Tax Anti-Court Act

The court held, in the opinion of Chief Justice Roberts, on this issue united by Ginsburg Judges, Breyer, Sotomayor and Kagan, that litigation over the validity of the mandate of the individual was not prohibited by the Anti-Injury Act, since the ACA listed the individual's mandate as " punishment "rather than" tax ", which prevents it from being treated as a tax under the Anti-Decision Act. The remaining four Judges - Scalia, Kennedy, Thomas and Alito in mutual disagreements - agree that the Anti-Disciplinary Law does not apply, but for different reasons: they think the mandate is not tax in the first place and labeling is fine.

The tax power of Congress

With a 5-4 vote, the Court upheld the mandate component of the ACA individual as a valid exercise of the congressional power to "lay and collect taxes" (Art I, Ã, §8, cl 1). Roberts, writing for the Court, explained:

The Affordable Care Act provisions that certain individuals pay fines for not obtaining health insurance can be considered taxes. Because the Constitution allows such a tax, not our role to ban it, or to continue its policy or justice.

Subsequently, the Court ruled that while the section 5000A penalty is treated as a tax for constitutional purposes, it is not a direct tax, and therefore is not required to be shared among countries according to the population. The Court concluded: "Taxes to be paid without health insurance are not included in the category of directly recognized taxes... The payment of joint responsibility is thus not a direct tax which must be shared among several States."

National Federation of Independent Business v.
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Other opinions

Issues supported by most Courts

The majority of judges approved the expansion of the ACA Medicaid and certain aspects of the constitutionality of the individual's mandate, although the Court did not issue official opinions on these issues.

Medicaid Expansion

Regarding the issue of Medicaid expansion, no opinion has been ordered for the support of a majority of judges. However, most Courts do indeed find expansion in some unconstitutional ways of forcing and deciding the coercive mechanism of the law.

  • Chief Justice Roberts, who joins Judge Breyer and Kagan, will decide that Medicaid expansion can survive, but states should be given the right to opt out of expansion without the loss of existing Medicaid funds.
  • Justice Ginsburg, joining Justice Sotomayor, will uphold overall Medicaid expansion (with non-participating countries losing all their federal Medicaid funding).
  • Judge Scalia, Kennedy, Thomas, and Alito will destroy the full expansion of Medicaid (along with the rest of the Law).

The constitutional scholars have questioned whether Roberts's view that states should be given the right to opt out without losing the Medicaid funds that already existed was a court of law, given that it only appealed to three judges, in addition to four judges who objected to the entire Medicaid provision in dissent but did not join Roberts's opinion.

Trade and Clause Clauses Required and Exactly

Regarding the question of whether the individual's mandate falls within the powers granted to Congress on the basis of the Trade Clause and the Necessary and Correct Clause, no opinion is united by the majority of Courts. However, the majority of Judges contend that the individual's mandate does not fall under this power.

  • Chief Justice Roberts will hold that the individual's mandate is beyond the power of the Necessary and Appropriate Congress, which distinguishes the mandate of federal prohibition on marijuana cultivation and ownership established at Gonzales v. Raich .
  • Judge Scalia, Kennedy, Thomas, and Alito will assume that the individual mandate is unconstitutional, for the same reason.
  • Ginsburg justice, joining Judge Judges, Sotomayor and Kagan, will assume that the individual's mandate is in the Commerce Clause and Necessary and Proper Clause clauses.

Chief Justice Roberts opinion

Justice Roberts, writing only for himself, would declare that the power of Congress to "regulate Trade" (Art "Trade Clause" I, Ã,§8, cl 3) does not include economic inactivity regulations.

A similar argument is made by mutual discrimination, even if the disagree does not join this section (or any part) of the opinion of the Chief Justice. So most judges argue that the individual's mandate does not fall within the power of Congress under the Trade Clause.

Regarding the argument that a punishable or "inactive" mandate, Roberts writes:

... very clearly the Constitution does not guarantee that individuals can avoid taxation through inactivity. Capitation, however, is a tax that everyone has to pay only for what exists, and capitulation is clearly contemplated by the Constitution. The Court today states that our Constitution protects us from federal regulations under Trade Conditions as long as we distance ourselves from our regulated activities. But from its creation, the Constitution makes no such promises in respect of taxes.

Further, five Judges including Roberts would argue that the individual's mandate is not supported by Necessary and Correct Clauses (Art I, Ã,§8, cl. 18).

The Court narrowed down Medicaid's penalty by deciding that the federal government can not withhold Medicaid funding from countries that choose not to participate in the Medicaid program extension. Judges Roberts, Breyer, and Kagan concluded that punishing the country for failure to comply with Medicaid expansion by withholding existing Medicaid funds (42 U.S.C. §1396c) was unconstitutional. Roberts notes "constitutional violations are completely overcome by blocking [Sebelius] from applying Ã,§1396c to withdraw existing Medicaid funds for failure to meet established expansion requirements", leaving other provisions of the ACA unaffected.

Hakim Agung Roberts menyimpulkan:

The Affordable Care Act is partially constitutional and partially unconstitutional. The mandate of the individual can not be established as a congressional exercise exercise under the Trade Clause. The clause authorizes Congress to regulate interstate commerce, not to order individuals to engage in it. In this case, however, it is reasonable to interpret what Congress has done as an increase in taxes for those who have a certain amount of income, but choose to leave without health insurance. Such laws exist within the power of Congress to impose taxes.

As for Medicaid expansion, part of the Affordable Care Act violates the Constitution by threatening existing Medicaid funds. Congress has no authority to order the State to govern in accordance with its instructions. Congress may offer State grants and require States to comply with the conditions attached to them, but States should have a genuine choice whether to accept the offer.

...

The Federal Government does not have the power to order people to buy health insurance. Section 5000A [of the Internal Revenue Code] will become unconstitutional if is read as a command. The Federal Government does has the power to impose a tax on those who do not have health insurance. Therefore Part 5000A is constitutional, as it can be read as tax .

Just Justice Ginsburg Approval/dissent

Judge Ginsburg concurred in a partial and disparate judgment. Joining Judge Breyer, Sotomayor, and Kagan, he will uphold the mandate of the individual under the Necessary and Proper Trade Clause and Clause:

Congress has a rational basis to conclude that non-insured, as a class, substantially affects inter-country trade. Those who do not have insurance consume billions of dollars of health care products and services each year. The goods are manufactured, sold, and shipped mostly by national and regional companies that routinely transact cross-border business. Uninsured persons also cross national borders to receive care.

Furthermore, merely joining Sotomayor, he disagreed with imposing the expulsion of Medicaid, arguing that it was under the control of Congress under the Expenditure Clause:

Basically, my colleague's position is that state dependence on federal funds limits Congressional authority to change its spending program. This puts things back: Congress, not America, is charged with spending federal money to serve the general welfare. And each successive Congress is empowered to obtain the appropriate funds as deemed necessary. When the 110th Congress reaches the conclusion of a Medicaid fund different from its predecessor's view, it sums up no State right to "exist", or "existing," funds.... For, in fact, there is no such funding. There is only money that countries anticipate receiving from the next Congresses.

Ginsburg's disagreements continue to highlight the implications of the majority's finding that the threat of the federal government taking existing funds from countries that do not want to implement Medicaid expansion leaves countries without "legitimate choice".

When the upcoming Clause Spend challenge arrives, because of their possibility will be behind today's decision, how will the litigation and judge assess whether "Does the State have a legitimate choice whether to accept federal conditions in exchange for federal funds"? Does the court measure the dollar amount that the Federal Government might incur for non-compliance? The portion of the State budget is at stake? And WHAT - or State - the budget determines: the main plaintiff, all the challenging nations (26 in this case, many with quite different fiscal situations), or some national median?

Dissent sharing

Judge Scalia, Kennedy, Thomas, and Alito joined with a vague disagreement stating that the individual's mandate was unconstitutional because it was a Congressional attempt to regulate beyond his rule under a trade clause. Furthermore, they argue that the reclassification of the Individual Mandate as a tax rather than a penalty for defending its constitutionality is not to interpret the law but to rewrite, which they consider to be a disturbing justice practice:

In answering that question [whether individual mandates are independently endorsed by the tax power of Congress] we should, if "very likely", Crowell v. Benson, 285 US 22, 62 (1932), interprets the provision of taxation rather than mandate-to-penalty, because it would make it constitutional rather than unconstitutional ( ut magical valeat quam pereat ). But we can not rewrite the law into what it is not. '' [A] lthough this Court will often strain to interpret the law so to keep it against constitutional attacks, it should not and will not take this to the point of transitioning the purpose of a law... 'Or legally rewrite. " Commodity Futures Trading v. Schor , 478 US 833, 841 (1986) (quotes Aptheker v. Secretary of State, 378 US 500, 515 (1964), in turn quotes Scales v. United States , 367 US 203, 211 (1961)). In this case, there is no way, "without violating the fair meaning of the words used", Grenada Regional Administrator v. Brogden, 112 US 261, 269 (1884), to escape from what Congress imposed: a mandate that individuals maintain minimum essential coverage, which is upheld by penalties.

The disagreement also denied Judge Ginsburg's statement that the court's opinion failed "to explain why the individual's mandate threatens our constitutional order":

[Individual mandate] threatens the order because it gives broad meaning to the Trade Clause that all personal actions (including failure to act) are subject to federal control, effectively destroying the government's share of power by the Constitution. Thus dissent, on the proposed theory for the validity of the Mandate, will change the constitutional relationship received between individuals and the National Government. The disagreement protests that a Necessary and Correct Clause has been held to include "the power to enforce the penal law,... the power to imprison,... and the power to create a national bank", ante, at 34-35. Is not the power to force buy health insurance is much lower? No, not if (unlike other dispositions) its application rests on the theory that everything is in federal control simply because it exists.

Finally, the joint disagreement states that because the ACA exceeds its constitutional powers in encouraging the purchase of health insurance and refuses funding of non-consenting Medicaid, all laws should be considered invalid as these two sections are at the center of the bill. and surgery. A joint disagreement states that "the Constitution requires a tax increase to come from the House of Representatives" as per the Origination Clause, although the issue is not dealt with by majority opinion.

Just Justice Thomas disagrees

In the difference of a paragraph, Judge Thomas emphasized his belief that the precedent of the Supreme Court has expanded the powers of Congress under the Trade Clause in a manner that is "inconsistent with the original understanding of the powers of Congress and with cases of Early Trade Clauses of this Tribunal". Thomas writes that he agrees with Roberts's interpretation of a precedent that allows Congress to use a trade clause to regulate "inter-state trade channels" and "persons or goods in interstate commerce" and prohibit the regulation of commercial activity. However, he disagrees with the third test, the "substantial effect" as defined by Wickard v. Filburn , articulated in the United States v. Morrison , and is reinforced by Gonzales v. Raich .

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Reactions and comments

Media coverage

The court held a meeting on the morning of June 28, 2012, to announce its decision on the ACA and two other cases; announced its decision on the ACA shortly after 10:00 am. CNN and Fox News initially reported that the individual's mandate was found to be unconstitutional, but self-corrected within minutes. President Obama initially heard from CNN and Fox News that the mandate has been found unconstitutional, but then heard the right information soon afterwards.

Speculation over Roberts sound

Immediately after the decision, there was speculation that mutual dissent was the opinion of the original internal majority, and that the voice of Chief Justice Roberts changed sometime between March and the public's decision to publish it.

On July 1, 2012, CBS News, citing anonymous sources in the Court, said that during the process Roberts's internal deliberations changed his position from dropping the mandate to enforce it. The article, written by journalist Jan Crawford, reports that during a private Court conference immediately after an oral argument, Roberts tended to impose a mandate but, in disagreement with the other four conservative judges, was not sure it was necessary to bring down the law as a whole. A news article in May 2012 that warned of potential "court damage - and Roberts's reputation - if the court had to impose a mandate" increased external pressure on Roberts, who "was well aware of his leadership role in the court [and] sensitive to how the court was perceived by the public", and more pay attention to media coverage of the Court rather than some of his colleagues. It was around this time that Roberts decided to enforce the law. One conservative judge reportedly pressured Roberts to explain why he changed his view of the mandate, but was "dissatisfied with his response".

On July 2, Adam Liptak of The New York Times reported that leaks could come from Justice Thomas, because Liptak pointed out that Crawford had long had a relationship with Thomas, gave rare interviews and Thomas picked him out. as his favorite reporter, says "There are great people here doing the job well - doing a fantastic job - like Jan [Crawford]."

Some observers put forward Roberts' philosophy of judicial control or the lack of precedent of the available Supreme Court "to say the individual's mandate across the constitutional line" plays a part in his decision. The article reports that after Roberts "survived for a month, a desperate campaign to bring him back to its original position", with Kennedy, who is usually the swaying vote in 5-4 decisions, leading the effort, conservatives basically tell him "you yourself. "Conservative disagreements are not signed and no, despite efforts by Roberts to convince them to do so, make every effort to join the Court's opinion, an unusual situation in which the four judges" deliberately ignore Roberts's decision, "the source said, as if they will not even want to get involved with it in the debate ".

Political reaction

President Obama hailed the decision in a series of statements, while discussing the benefits of the law in a statement shortly after the decision. Former House Speaker Nancy Pelosi said that Senator Edward Kennedy of Massachusetts, a longtime supporter of health care reforms who died before the bill became law, can now "rest".

The decision quickly became a call for Republicans who criticized the Supreme Court's reasons and vowed to uproot the ACA. Although they have repeatedly tried to do so starting in January 2011, they are not successful in enforcing the retraction. The Conservatives quickly grasped the fact that Obama and his supporters of the bill insisted repeatedly during the prolonged political debates of 2009 and 2010 that the mandate was not a tax, but the Supreme Court upheld him on the grounds that it was a tax. Republican presidential candidate Mitt Romney said he would lift the bill, as did House Speaker John Boehner and Senate Minority Leader Mitch McConnell. A campaign spokeswoman Romney announced that they raised more than $ 3.2 million within hours of the announcement of the decision. Several state attorneys opposing the law state that they are disappointed by the final decision of the Supreme Court but are pleased that in doing so, the Court limits the powers of Congress under a trade clause. Some Republican state officials indicated their intention to use the option given to them by the Supreme Court not to further extend Medicaid.

The American Medical Association, the National Physicians Alliance, the American Academy of Pediatrics, and the Association of American Medical Colleges say that the decision is a victory.

The New York Times reported the decision "might secure Obama's position in history".

Academic comments

The New York Times reported that the court decision was the most significant federal decision since the New Deal. It reports in this case about the new boundaries of decisions placed on federal trade regulations and on the conditions the federal government may enforce the money it gives the state. In connection with the Trade Clause, the Court ruled that the federal government does not have permission to force individuals not involved in commercial activities to purchase services they do not want. In relation to Medicaid's expansion under the Affordable Care Act, the Supreme Court stated that the ACA requirement which states rapidly expand coverage for new beneficiaries or loss of existing federal payments is too compelling. Healthcare laws should allow countries to choose between participating in expansion when receiving additional payments, or not continuing to expand and maintain existing payments. Cuccinelli praised the boundaries of the Courts placed on federal trade regulations and on the condition that the federal government could enforce the money giving the state.

Randy Barnett at SCOTUSblog stated that by dismissing existing Medicaid fundraising because it unconstitutionally forced the Supreme Court to find a workable limit on the federal Government's Spending Authority. Limits on Power This federal government spending is part of Neal K. Katyal's ruling analysis. Law professor Neal K. Katyal at Georgetown University, who acts as a lawyer acting commonly in the United States and raising health care cases on appeal, argues that a Supreme Court ruling may alter the relationship between the federal and state governments because "the existence of an extronitional limit "on the strength of the federal government under the Expenditure Clause. Katyal said that to date it has been understood that when the federal government gives money to the state in return for the state to do something, the federal government is free to do so as long as there is a reasonable relationship between federal funds and such action. the federal government wants the state to do. He later referred to the Court stating that the ACA requirement which states quickly extend Medicaid coverage to new beneficiaries or the loss of existing federal payments is too coercive by noting that the court finds that "the threat is coercive and that states can not be punished because it does not extend their Medicaid coverage after receiving the funds, and it does so in the context of Medicaid, which Congress created and can change, alter or delete at any time.... This is the first significant loss for federal government spending power in decades. it was used by the courts to see the act as coerced back in later cases to haunt the federal government. Many programs are built on the power of government spending, and the existence of extronsstitutional restrictions on that force is an alarming development. "Katyal also mentioned that the federal government told the court that the old law contains clauses that condition money on the country's performance of certain activities. "The decision leaves questions about whether those actions, and many others (such as the Clean Air Act), are now unconstitutional as well." However, Reuters reported later that Katyal reversed her opinion and stated that she did not see any litigation issued from the Supreme Court in the near future.

In the same direction as Katyal argues Kevin Russell, who teaches Supreme Court litigation at Harvard and Stanford Law Schools and signs up for Judge William Norris of the Ninth Circuit and Judge Stephen Breyer. According to him, some significant civil rights legislation, enacted under the Power of Spending of Congress, risks being unconstitutional, since the Court states that Congress exceeds the authority of Clause Spending by forcing countries into an all-or-nothing option with threatened to withdraw all of their Medicaid funding if they did not participate in the Medicaid expansion. Russell recalled that a decade ago some countries made a challenge to a number of important civil rights legislation that conditioned the acceptance of federal funds on state treaties to adhere to the principles of non-discrimination in federally funded programs. "This Act includes Title IX (sex discrimination in federally funded education programs), Title IV (racial discrimination in any federally funded program), and the Rehabilitation Act (disability discrimination in federally funded programs) Countries argue that by threatening to take all of the program's funds if the State does not agree to comply with this law, Congress is involved in unconstitutional force. "

David B. Kopel, a professor of constitutional law at the University of Denver, said that the Supreme Court ruling is the court's most important verdict in determining the limits of congressional powers under the Expenditure Clause, as this clause should, like other congressional powers, be in accordance with the principles of state sovereignty embodied in the United States Constitution, the Tenth Amendment and the Eleventh Amendment. According to him this has a tremendous impact on the state budget: "Today (and from now on!), The State does not need to provide Medicaid for healthy children without children.Similarly, countries today have a wisdom on whether to provide Medicaid to middle-class parents.No doubt, some countries will choose to participate in the widespread expansion of ACA's medical welfare, but fiscally responsible countries now have the option of not doing it. "

Professor Samuel Bagenstos, University of Michigan law professor, told The Atlantic that holding the Court on Medicaid Expansion could be an important decision in federalist jurisprudence, if Medicaid issues are not in the same case as individual mandates. He considers it a "big deal" that the Supreme Court for the first time has already imposed conditions on federal spending on the grounds that it forced states. According to him this means that a number of federal laws that are not really subject to effective legal challenges before now can be challenged by the state.

Summary of Public Opinion

Fairleigh Dickinson University PublicMind conducts research on a public constitutional perspective by requesting registered voters on the main legal issues posed by PPACA litigation through two surveys based on random sampling of the US population. The authors, Bruce G. Peabody and Peter J. Woolley argue that, through public response to the case, that despite the claims of an ignorant and ignorant society, the masses can become confident, totally conflicted, and principled when considering controversy and major dilemmas. Instead of a public poll on raw personal opinion, the study asked into a random voter judgment judgment on the constitutionality of PPACA. For example, 56% of Americans (per February 2012) assume that Congress has no legal right to require everyone to have health insurance, while 34% believe that such a mandate is legally permissible.

National Federation of Independent Business v.
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See also

  • 2011 term opinion from the United States Supreme Court
  • King v. Burwell
  • Sebelius v. Hobby Lobby

United States v. Morrison | quimbee.com - YouTube
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References


America and Globalization (1990-Present) - ppt download
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External links

  • Slipped an opinion from the US Supreme Court
  • Online symposium: Bar Reviews Version of NFIB v. Sebelius

Source of the article : Wikipedia

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