King v. Burwell

King v. Burwell was a landmark decision by the Supreme Court of the United States in 2015 that upheld a critical component of the Affordable Care Act. The case centered on whether federal tax credits for health insurance were available to residents of states that used the federally facilitated health insurance exchange established by the U.S. Department of Health and Human Services. In a 6–3 ruling, the Court held that the credits were lawful nationwide, preventing a major disruption to the nation's healthcare system.

Background and legal context

The legal challenge emerged from a specific provision in the Affordable Care Act concerning the establishment of state exchanges. The Internal Revenue Service issued a rule interpreting the law to allow tax credits for insurance purchased on any exchange, whether run by a state or the federal government. Opponents, including plaintiffs David King and three other Virginia residents, argued the text of the Affordable Care Act only authorized subsidies for plans purchased "through an Exchange established by the State." This interpretation, if accepted, would have made credits unavailable in the roughly 34 states that declined to establish their own exchanges and relied on the federal HealthCare.gov platform. The case was litigated in the United States District Court for the Eastern District of Virginia and the United States Court of Appeals for the Fourth Circuit before being granted certiorari by the Supreme Court of the United States.

Supreme Court proceedings

Oral arguments were held on March 4, 2015. The petitioners were represented by Michael Carvin, while the Obama administration's position was defended by Solicitor General Donald Verrilli Jr.. The justices intensely scrutinized the statutory text, the consequences of the petitioners' interpretation, and the overall structure of the Affordable Care Act. Key questions involved whether the phrase "established by the State" was ambiguous and whether the Internal Revenue Service's interpretation under Chevron deference was permissible. The Supreme Court of the United States also considered briefs from numerous amicus curiae, including states like Indiana and organizations such as the American Hospital Association.

Majority opinion

Chief Justice John Roberts delivered the opinion for the 6–3 majority. The Court declined to apply Chevron deference, finding the question of tax credit availability was too significant to delegate to agency interpretation. Instead, the majority analyzed the Affordable Care Act as a whole, concluding that the petitioners' "plain meaning" interpretation would create a "death spiral" in insurance markets and was contrary to the law's fundamental purpose of expanding coverage. The opinion stated that the phrase "an Exchange established by the State" must be read in context to include exchanges established by the federal government on a state's behalf, thereby making tax credits available in all states.

Dissenting opinions

Justice Antonin Scalia authored a fiery dissent, joined by Justices Clarence Thomas and Samuel Alito. Scalia accused the majority of rewriting the law to save it, famously calling the interpretation "pure applesauce" and "interpretive jiggery-pokery." He argued that the text was unambiguous and that the Supreme Court of the United States's role was to apply the law as written by Congress, not to fix perceived flaws. The dissent warned that the decision eroded the separation of powers and set a dangerous precedent for statutory interpretation.

Implications and impact

The decision had immediate and profound consequences for the Affordable Care Act and healthcare in the United States. It preserved tax credits for millions of Americans in states using the federal exchange, averting a projected collapse of individual insurance markets. The ruling solidified the legal foundation of the Obama administration's signature domestic policy achievement and removed a major existential threat following the earlier challenge in National Federation of Independent Business v. Sebelius. Politically, it forced opponents of the law to focus on legislative repeal efforts in Congress. The case remains a defining example of statutory interpretation and the Supreme Court of the United States's role in major social policy disputes.

Category:United States Supreme Court cases Category:Affordable Care Act Category:2015 in United States case law