Bondi v. U.S. Dep’t of Health and Human Servs. (Summary)

HEALTH REFORM

Bondi v. U.S. Dep’t of Health and Human Servs., No. 3:10-cv-91-RV/EMT (N.D. Fla. Jan. 31, 2011)

The U.S. District Court for the Northern District of Florida granted summary judgment in favor of the state and individual plaintiffs, concluding that The Patient Protection and Affordable Care Act was unconstitutional and must be declared void in its entirety. The court also denied the plaintiffs’ request for injunctive relief because it is unnecessary where an award of declaratory relief is adequate.

The court determined that the Act exceeded existing legal boundaries established by Supreme Court precedent in that Congress may not regulate economic inactivity, the economic decision to not purchase a product or service in anticipation of future consumption, because the Commerce Clause requires activity. The mandate violates the Clause as it significantly expands and alters the Medicaid program to such an extent they cannot afford the newly imposed costs and burdens, and such law can only be expanded by the Supreme Court or a Constitutional amendment.

The individual mandate exceeded Congress’s power under the Commerce Clause and could not be saved by the Necessary and Proper Clause, as the exercise of power was not proper. The individual mandate for health insurance was an essential and indispensable part of the health reform effort, and that Congress did not believe that the other parts of the Act could survive independently. As such, the individual mandate could not be severed from the Act, and the entire Act is void.

 

On March 3, 2011, the United States District Court for the Northern District of Florida stayed its declaratory judgment pending appeal of the decision. Florida v. U.S. Dept. of Health and Human Servs., No. 3:10-cv-91-RV/EMT (N.D. Fla. Mar. 3, 2011).”