Mead v. Holder (Summary)

HEALTH CARE REFORM

Mead v. Holder, Civil Action No. 10-950(GK) (D.D.C. Feb 22, 2011)

The United States District Court for the District of Columbia granted the United States government’s motion to dismiss a suit brought by individual taxpayers challenging the individual mandate provision of the Affordable Care Act (“ACA”) as unconstitutional and violating the Religious Freedom Restoration Act (“RFRA”).

The district court first concluded that the taxpayers were proper individuals to bring such a suit because of allegations that the individual mandate would inflict the future injury of having to make annual shared responsibility payments under the ACA and the present injury of needing to rearrange their current finances in anticipation of the mandatory payments.

However, the district court determined that the government had the authority under the Commerce Clause of the Constitution to enact the individual mandate. This determination was based on the court’s findings that both the decision to buy and the decision not to buy health insurance were “clearly economic ones” and “the aggregate of individual decisions not to purchase health insurance substantially affects the national health insurance market.” Furthermore, the individual mandate did not violate the Necessary and Proper Clause of the Constitution because “individual mandate provision is an appropriate means which is rationally related to the achievement of Congress’s larger goal of reforming the national health insurance system.” Conversely, the government could not rely on the General Welfare Clause of the Constitution because it intended the individual mandate to operate as a penalty and not a tax.

Lastly, the district court held that RFRA was not violated by the enactment of the individual mandate, holding that it “does not place a substantial burden on the exercise of [the] plaintiffs’ Christian faith, and even assuming that it does, [the mandate] is the least restrictive means of serving a compelling governmental interest.”