Missouri Healthcare Freedom, Proposition C (August 2010)

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The Missouri Healthcare Freedom Act, also known as Proposition C, was on the August 3, 2010 ballot in Missouri as a legislatively-referred state statute, where it was approved.[1][2][3]

The proposed measure aimed to block the federal government from requiring people to buy health insurance and banned punishment for those without health insurance.[4][5][6]

Backers of such measures were opposed to President Barack Obama’s new health care plans. The measure did not advocate a particular plan but measure advocates said the measure would "protect the individual’s right to make health care decisions." Opponents of the measures and some constitutional scholars said the proposals were mostly symbolic, intended to send a message of political protest, and had little chance of succeeding in court over the long run.[7]

On May 4, 2010 the Missouri State Senate voted 26-8 in favor of referring the proposed measure to the ballot.[8] On May 11 the House gave final approval to refer the measure to the ballot following a 108-47 vote.[9][10][11]

Although similar measures were scheduled to appear on other 2010 statewide ballots, Missouri's Proposition C marked the first time voters had a say on blocking the federal government's 2010 health care reform.[12]

A "yes" vote was a vote to amend current Missouri law to deny the government authority to "penalize citizens for refusing to purchase private health insurance or infringe upon the right to offer or accept direct payment for lawful healthcare services." A "no" vote was a vote to reject the proposed referendum.

Reports out of Missouri predicted a low turnout of voters on August 3, as there were no television advertisements or debates on the matter in the low-key campaign. The Missouri Secretary of State expected a voter turnout of 24 percent.[13]



Shortly following the August 3 vote, ALEC board member and Missouri Senator Jane Cunningham said, "The people of Missouri sent a clear message to the President and Congress: we don't want government-mandated health care."

The Missouri measure was modeled after the American Legislative Exchange Council's (also known as ALEC) Freedom of Choice in Health Care Act, which has been introduced in several states across the country. ALEC Health Task Force Director Christie Herrera said, "Proposition C will give Missourians the ultimate exit strategy at a time when Americans are faced with an unconstitutional federal requirement to purchase health insurance."[14]

Lt. Gov. Peter Kinder, who supported the measure being placed on the ballot, said, "What we saw in Missouri was an F-5 tornado touch down and move across all 114 counties, leaving very little left of the federal health care law. It was passed by such an overwhelming margin in every part of the state, with tens of thousands of Democrats voting for it."[15]

Months after the vote, a majority of likely voters in Missouri continued to oppose federal health care reform, according to a poll released by Missouri Foundation for Health. The poll found 54 percent do not support the federal health care reform law. The survey for MFH was conducted in late August by polling 800 likely general election voters across Missouri. "[16]

The Supreme Court will ultimately decide if the federal health care mandate is constitutional, said Elizabeth Price Foley, a law professor at Florida International University, who specializes in constitutional and health care law. If the Supreme Court decides in favor of the federal government, the decision will be the law of the land and residents in Missouri will be required to buy health care insurance, even though voters passed Prop C in August, she said. "Prop C is unenforceable as a legal matter, if the federal courts rule that health reform is constitutional, Foley said. "[17]

Finance reports

According to campaign finance reports released in early September 2010 supporters, Missourians for Health Care Freedom, raised about $125,000 and spent an estimated $114,000 promoting Proposition C.[18]

Election results

Missouri Proposition C (August 2010)
Approveda Yes 669,847 71.07%

Election results via the Missouri Secretary of State's website.

Text of measure

See also: Full text of the measure
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Ballot Title

The official ballot title read as:[19]

Shall the Missouri Statutes be amended to:
  • Deny the government authority to penalize citizens for refusing to purchase private health insurance or infringe upon the right to offer or accept direct payment for lawful healthcare services?
  • Modify laws regarding the liquidation of certain domestic insurance companies?
It is estimated this proposal will have no immediate costs or savings to state or local governmental entities. However, because of the uncertain interaction of the proposal with implementation of the federal Patient Protection and Affordable Care Act, future costs to state governmental entities are unknown.


Fair Ballot Language

A “yes” vote will amend Missouri law to deny the government authority to penalize citizens for refusing to purchase private health insurance or infringe upon the right to offer or accept direct payment for lawful healthcare services. The amendment will also modify laws regarding the liquidation of certain domestic insurance companies.

A “no” vote will not change the current Missouri law regarding private health insurance, lawful healthcare services, and the liquidation of certain domestic insurance companies.

If passed, this measure will have no impact on taxes.



In May 2010 media reports said that local consultant Patrick Tuohey filed paperwork to establish a committee in support of the proposed health care freedom measure.[21] The official group in support of Proposition C is Missourians for Health Care Freedom.[22]


  • Sen. Jane Cunningham, a sponsor of the proposed measure, argued that the measure was about protecting personal liberties and allowing Missouri residents to choose whether to accept federal health care without any penalties. "Missourians will lose absolutely nothing if this amendment passes. They can choose the government plan or they can choose anything else they want," said Cunningham. But some lawmakers argued that the health care legislation crosses into states' rights and oversteps its own federal power. Sen. Jim Lembke said,"If the federal government is going to make all the decisions for us, why are we here?"[23]
  • In a July 25 blog post, the Citizens Commission on Human Rights of St. Louis said, "We think voting for this is a good idea because the recently passed federal Patient Protection and Affordable Care Act is laden with language and funding for the psycho/pharmaceutical industry, which has a vested interest in seeing every man, woman and child in America labeled with some mental disorder and prescribed harmful psychiatric drugs."[24]
  • Carl Bearden, executive director of United for Missouri, said, "Quite simply, United for Missouri believes that the federal health care package pushed by the president and supported by the Democratic Congress treads on states' rights. It's a mandate on individuals and states that goes beyond proscribed federal powers."[25][26]
  • A co-sponsor of the proposed measure, Rep. Ed Emery, said, "It’s unsustainable anyway, but it’s more quickly unsustainable if you can get out of it," of the 2010 federal health care reform. In regard to the proposed measure, Emery said, "This is the most fundamental Constitutional battle. We have, little by little, been losing the principles of federalism. This is our chance to take a stand and make America like America is supposed to be."[27]


Senator Jane Cunningham on Prop C, Part 1, 7-17-10

According to the quarterly finance report filed July 15, Missourians for Health Care Freedom received several donations from June 18 through June 30. According to reports, the group received $22,768.07 in monetary contributions.[28] According to the finance report, the group has had a total of $9,700 in expenditures.[29]

Below is a chart that outlines major cash contributions to Missourians for Health Care Freedom:[29]

Contributor Amount
Citizens for Brad Lager $5,000
Missourians for Goodman $5,000
Ray Vinson, Executive for US Auto Protection $5,000
William Canfield, retired[30] $5,000
Fred Sauer, Orion Investment Co.[31] $5,000
Missourians for Mayer $2,500
Ron Richard 2010 $2,500

Campaign advertising

The Missourians for Health Care Freedom began running radio ads on July 26 in support of the proposed measure. According to reports, the radio ads ran during conservative talk shows and on Christian radio stations.[32]

Tactics and strategies

In the last week prior to the August 3 primary vote, supporters held various rallies and fundraisers. On July 28, 2010 Missourians for Health Care Freedom held a fundraiser/rally at The Columns Banquet Center in St. Charles, Missouri. According to the campaign's website, attendees included Sen. Jane Cunningham, Sen. Jim Lembke, Rep. Tim Jones and Rep. Brian Nieves.[33] Another fundraiser is scheduled for July 29 and a rally is scheduled for July 31 at the corner of Brentwood and Manchester between 12 and 2 pm.[34]



Opponents argued that the approved federal health care legislation was similar to a mandate, requiring lawmakers to cover treatment for autistic children - approved in March 2010 by the Missouri State Senate. In response to supporters' arguments Sen. Victor Callahan said, "Social Security per se is not in the Constitution. I don't see it in the Constitution but it appears to be on my check every two weeks."[23]


  • On July 23, 2010 the League of Women Voters of Missouri came out in opposition to Proposition C, arguing that, "The new federal law, the Patient Protection and Affordable Care Act, provides universal coverage with access to affordable, quality care for all Americans . . . Proposition C undermines a key component of the law by allowing Missourians to opt out of buying health insurance without having to pay a penalty. League opposes this proposal."[36]
  • On July 24, 2010, the Missouri Hospital Association urged voters to consider that, "Proposition C would only reinforce a broken system." The Association suggested that Missourians should consider that it was, "unfair for Missourians who pay for health insurance to pay higher insurance premiums to cover the cost of care for those who decide not to buy insurance."[37]
  • Ruth Ehresman, the director of health and budget policy for the Missouri Budget Project, wrote in an editorial, "A 'no' vote on Proposition C will allow Missouri — and the rest of the nation — to focus on planning how to implement federal reform well and how to improve parts that might need changing. Those wishing to make political statements should be careful to not do it at the expense of the estimated 500,000 Missourians who will gain access to affordable health insurance through federal reform. Voting 'no' on Proposition C is a wise choice."[38]
  • Brian B. Zuzenak, the executive director of the Missouri Democratic Party, made the argument that the measure would change nothing and was a waste of the state's time. According to Zuzenak, “The proposition will have no legal standing, so I don’t know why there’d be a reason to focus on it. From the beginning, we’ve said it’s meaningless and unconstitutional. At best, it’s a ploy by the Republicans to get their base excited.”[13]
  • Saint Francis Medical Center president and chief executive officer Steven C. Bjelich said, "Eliminating the federal health insurance mandate will significantly reduce the number of Missourians otherwise expected to obtain coverage under the Affordable Care Act. This will have negative consequences for Missouri hospitals, because they will experience Medicare and disproportionate-share hospital payment reductions designed to fund higher levels of coverage."[39]


The Missouri Hospital Association spent more than $400,000 sending out fliers opposing the proposed measure. Eliminating the federal health insurance mandate in Missouri would reduce the number of residents expected to obtain health coverage, according to the MHA. This would negatively hurt hospitals because they would receive lower payments designed to fund higher levels of coverage.[40][41] [42]

Campaign advertising

On July 26 opponents of the proposed measure began running radio ads calling for voters to vote "no" on Proposition C.[32]

Tactics and strategies

Opponents of the proposed measure and supporters of the approved federal health care reform created a group on Facebook called "Vote No on Missouri Prop C." The group, however, did not list an official website. According to the group's logo, the motto read, "Protect Health Care For All Missourians: No! on Prop C."[43]

A blog was created on blogger.com called "Vote No Prop C in Missouri." (dead link) The blog highlighted a rally, scheduled for July 29th at 5 pm. The rally was scheduled to be held in Kansas City, Missouri at the intersection of 47th street and J.C. Nichols Parkway.[44][45]

Media editorial positions

Main article: Endorsements of Missouri ballot measures, 2010


  • Kansas City Star said, "Supporters are calling Proposition C on the Missouri statewide ballot the 'Health Care Freedom Act.' It more accurately could be called the 'Futile Gesture Act.' Or perhaps the 'Full Employment for Lawyers Act.' The ballot measure is an empty protest of federal health care reform, instigated by an advocacy group amply funded by health insurers and drug companies. Besides its expense in printed ballots, the measure could end up costing taxpayers plenty in legal fees. Missouri voters should say 'no' on Aug. 3."[46]
  • St. Louis Business Journal said, "This measure pits some of the largest corporations and their leadership against the largest health-care institutions (which, not so ironically, are themselves large employers) and their leadership. The corporate leaders and the political leaders who share their sentiments see requiring health-care insurance as infringing on individual freedom. The health-care leaders point to car insurance as an example of a government mandate requiring individuals to submit to the rule of the sovereign...We hope you’ll vote against Prop C."[47]
  • St. Louis Post-Dispatch said, "Proposition C is nothing but a taxpayer-funded political exercise designed to raise cash for Republican candidates, consultants and causes. No wonder they call it Prop C...they should reject the August charade and Vote No on Proposition C."[48]


See also: 2010 post-certification removal litigation

A lawsuit was filed in late June 2010 in the Cole County Circuit Court in an attempt to block Proposition C from appearing on the ballot. According to reports the lawsuit argued that the proposed measure violated the Missouri Constitution because of the way - as a legislatively-referred constitutional amendment - in which it was certified for the ballot.[49] Specifically plaintiffs cite a constitutional prohibition against bills containing multiple subjects. Originally the measure addressed procedures for "insurance companies to voluntarily dissolve. It was amended to include a section stating that people cannot be compelled to have health insurance or penalized for paying their health bills with their own money."[50]

In reaction to the lawsuit Sen. Jim Lembke said, "...a few liberals in this state that want to settle things...in the courts, instead of allowing the people of Missouri to vote on this issue." Sen. Jane Cunningham said that the lawsuit is being pursued because opponents "know they can't win at the ballot box." However, Charles Gentry, the attorney who filed the suit argues that the suit is not about preventing voters from having a say on the measure but to protect "the referendum and ballot process."[51]

The case was heard on July 13, 2010.[52]


At the July 13 hearing, attorney Chip Gentry argued that the proposed measure included multiple subjects, violating the single subject rule. "The fact that we have two questions and one box forces Missouri voters into a conundrum' and underscores the fact that lawmakers used 'logrolling' to combine multiple subjects into one bill," said Gentry. State Solicitor Jim Layton, on the other hand, said that both parts of the legislation were focused on the topic of insurance. Additionally Layton noted that voters had in the past voted on measures with several components. Specifically Layton referred to Amendment 2 in 2006 which defined and outlawed human cloning. Additionally, the measure prohibited the Missouri Legislature from denying funding to entities that performed human embryonic stem cell research.[53][54]

The case was heard by Cole County Circuit Judge Paul Wilson. Wilson did not issue a ruling on July 13 but said he planned to issue one as quickly as possible. According to reports Wilson wanted to allow time for appeals and a Missouri Supreme Court decision.[53][55]

Ruling: measure upheld

On Friday, July 16, Cole County Circuit Court Judge Paul Wilson dismissed the lawsuit against Proposition C.[56] In his decision, Judge Wilson wrote that despite arguments that the measure's title was too broad, the Missouri Supreme Court had previously upheld bills that had broader titles. Additionally, Wilson noted that both parts of the proposed measure related to insurance and thus complied with the single subject rule. The changes made to the text, he noted, remained in line with the bill's original purpose.[57][58]

In his decision Judge Wilson criticized the timing of the suit. He noted that the plaintiffs had more than sufficient opportunities to file a complaint prior to the lawsuit filing.[59]

No appeal sought

In reaction to the July 16 court ruling, Jefferson City Attorney Chip Gentry announced that the plaintiffs did not plan to further pursue the case. "We thought about it and have decided not to appeal at this time; in light of the fact that ultimately what this case was about was to avoid voter confusion and the impossible choice of having two questions in one box. Even if we were successful on appeal, which we feel we would be; the ultimate remedy of actually removing that confusing language from the ballot wouldn’t happen and that the ballots simply would not be counted and would not be certified," said Gentry. In addition to bad timing, Gentry said the plaintiffs did not want to cost the state more money. Absentee ballots had already been cast and ballots had already been printed.[60][61]

Despite the plaintiffs' decision not to appeal the judge's ruling, a challenge following the August election, should the measure be approved, had not been out of the question.[60]

National lawsuit

On July 7 Lt. Gov. Peter Kinder filed a lawsuit against the federal health care bill. Kinder initially announced his intent to file a lawsuit in May 2010. According to reports, the lawsuit asserted that the federal government cannot compel people to buy a product and cannot require state officials to participate in enforcing a "federal scheme."[62] The lawsuit was filed by Kinder and three other Missouri residents - Samantha Hill, Dale Morris and Julie Keathley. The suit was filed in U.S. District Court in Cape Girardeau. Kinder is reportedly raising private money for the lawsuit.[63][64]

With United States President Barack Obama signing the passed federal health care bill into law, many states began preparing themselves to combat the health care mandates that are on the verge of taking place across the country. Some states have pending initiatives or legislative referrals for the statewide ballots, however, in other states attorney generals were joining in a national lawsuit.[65][66]


See also: Polls, 2010 ballot measures
  • In a July 19-21, 2010 poll conducted by Mason-Dixon Polling & Research (dead link) and commissioned by Post-Dispatch/KMOV-TV (Channel 4) a total of 300 likely Democratic primary voters and 300 likely Republican primary voters were polled on Proposition C. According to the results, 67% of Republicans said they planned to vote yes, 16% said no and 17% said they remained undecided. Of the 300 Democrats polled, 27% said yes, 48% said no and 25% said they were undecided. The margin of error was reported to be 6 percentage points. Additionally, according to reports, 61% of the total number of registered voters polled said they were opposed to the health care law passed by Congress in March 2010.[67]

Date of Poll Pollster In favor (Repub.) Opposed (Repub.) Undecided (Repub.) In favor (Dem.) Opposed (Dem.) Undecided (Dem.)
July 19-21, 2010 Mason-Dixon Polling 67% 16% 17% 27% 48% 25%

Path to the ballot

See also: Missouri legislatively-referred state statutes
  • On May 11 the House gave final approval to refer the measure to the ballot following a 108-47 vote.[9]

Similar measures in other states

Groups in Indiana, New Mexico, North Dakota and Wyoming are considering a similar proposal. Two of these states (North Dakota and Wyoming) allow ballot initiatives; in the other three states, the state legislature would have to vote it onto the ballot using their state's procedure for constitutional amendments.[74]

The "Health Care Freedom" or "Health Care Choice" legislation introduced in many states since the passage of the Affordable Care Act are based on model legislation and campaigns from the American Legislative Exchange Council (ALEC). This think tank, promotes "limited government, free markets and federalism." In 2008, prior to the passage of health reform, ALEC adopted the model legislation which is mirrored by several state measures, including Missouri's August 2010 measure.[75]

Proposed ballot measures that were not on a ballot Indiana Health Care Freedom Act
Proposed ballot measures that were not on a ballot Minnesota Health Care Freedom Act (2010)
Proposed ballot measures that were not on a ballot New Mexico Health Care Freedom Act (2010)
Proposed ballot measures that were not on a ballot North Dakota Health Care Freedom Act (2010)
Proposed ballot measures that were not on a ballot Wyoming Health Care Freedom Act (2010)

See also

Suggest a link


External links

Text and content

Additional reading




  1. St. Louis Post-Dispatch, "Prop C passes overwhelmingly," August 4, 2010
  2. The Detroit Free Press, "Most Missourians vote down health insurance rule," August 8, 2010
  3. Time, "Mixed Results on the Health Reform Referendum," November 2, 2010
  4. KOMU, "Missouri Takes Step To Block National Health Care Plan," March 4, 2010
  5. Associated Press, "Missouri House seeks to block health insurance mandate," March 3, 2010
  6. The Columbia Daily Tribune, "Missouri legislators OK referendum on health care," May 12, 2010
  7. New York Times, "Health Care Overhaul and Mandatory Coverage Stir States’ Rights Claims," September 28, 2009
  8. Missourinet, "Senate approves healthcare mandate referendum," May 4, 2010
  9. 9.0 9.1 Associated Press, "Mo. to vote in August on health insurance mandate," May 11, 2010
  10. The State Column, "Missouri Voters to Decide Fate of Health Care," May 12, 2010
  11. The Seattle Post-Intelligencer, "Mo. to vote in August on health insurance mandate," May 11, 2010
  12. Kansas City Star, "Missourians to vote on Proposition C, which relates to purchase of health insurance," July 27, 2010
  13. 13.0 13.1 New York Times, "Missouri to Vote on Health Law," July 31, 2010
  14. ALEC, "ALEC Applauds Missouri Vote to Allow Health Care Act to Proceed," August 4, 2010
  15. The Examiner, "Missouri fights health care reform," September 8, 2010
  16. "Poll: 54 percent oppose health care reform in Missouri" Missouri Watchdog, October 6, 2010
  17. Missouri Watchdog, "Kinder praises ruling on federal health care law," December 13, 2010
  18. Associated Press, "Missouri health measure supporters spent $100,000-plus," September 2, 2010
  19. Missouri Secretary of State, "2010 ballot," accessed June 10, 2010
  20. Note: This text is quoted verbatim from the original source. Any inconsistencies are attributed to the original source.
  21. Kansas City Star, "Committee to support health care repeal referendum formed," May 21, 2010
  22. Missourians for Health Care Freedom, "Main page," accessed July 14, 2010
  23. 23.0 23.1 Associated Press, "Mo. Senate Considers Rejecting Health Care Mandate," March 25, 2010
  24. Citizens Commission on Human Rights of St. Louis blog, "Vote for Missouri Proposition C," July 25, 2010
  25. Southeast Missourian, "PRO: Prop C would send a strong message," July 25, 2010
  26. Kansas City Star, "Vote ‘yes’ on Proposition C," July 27, 2010
  27. Bolivar Herald-Free Press, "Prop. C will protect Missourians’ health care choices, lawmaker says," July 28, 2010
  28. Associated Press, "Backers of Missouri measure defying federal health care law raise $23,000," July 16, 2010 (dead link)
  29. 29.0 29.1 Missouri Ethics Commission, "Missourians for Health Care Freedom finance report," July 15, 2010
  30. Missouri Ethics Commission, "Missourians for Health Care Freedom - finance report of contributions of more than $5,000 (1)," July 19, 2010
  31. Missouri Ethics Commission, "Missourians for Health Care Freedom - finance report of contributions of more than $5,000 (2)," July 19, 2010
  32. 32.0 32.1 Associated Press, "Radio ads begin for Missouri measure opposing federal health care reform," July 26, 2010 (dead link)
  33. Missourians for Health Care Freedom, "July 28 fundraiser," accessed July 28, 2010
  34. Missourians for Health Care Freedom, "Main Page - Into the Final Stretch!," accessed July 28, 2010
  35. Missouri Jobs with Justice, "August 3 Primary Election, Vote No on Prop C," accessed July 26, 2010
  36. Missourian, "League of Women Voters of Missouri Opposes Proposition C," July 24, 2010
  37. Southeast Missourian, "Learn More About Prop C Before You Vote," July 26, 2010
  38. Columbia Daily Tribune,"‘No’ vote would let Missourians tackle real issues," July 27, 2010
  39. The Daily Dunklin Democrat, "Ballot measure tests federal health care law," August 1, 2010
  40. Missouri Ethics Commission, "Non-committee Expenditure Report - Missouri Hospital Association," July 21, 2010
  41. St. Louis Post-Dispatch, "Missouri Hospital Association joins fight against Prop C," July 27, 2010
  42. "Missouri Watchddog,""Hospitals spend more than $400,000 to oppose Prop C," August 3, 2010
  43. Facebook, "Vote No on Missouri Prop C," accessed July 21, 2010
  44. Vote No Prop C, "Rally in KC Thursday," July 27, 2010 (dead link)
  45. Associated Press, "Opposition organizing to Mo. health care measure," July 27, 2010
  46. Kansas city Star, "Missouri voters should reject pointless Proposition C on health care," July 23, 2010
  47. St. Louis Business Journal, "Vote ‘No’ on Prop C," July 23, 2010
  48. St. Louis Post-Dispatch, "Prop. C would protect health care freeloaders at our expense.," July 22, 2010
  49. Associated Press, "Lawsuit challenges Mo. health care referendum," June 23, 2010
  50. Jefferson City News-Tribune, "Lawsuit challenges Missouri referendum on national health care law," June 23, 2010
  51. The News Tribune, "Bill's sponsors decry lawsuit," June 30, 2010 (dead link)
  52. Associated Press, "Mo. judge to hear challenge to health care measure," July 13, 2010
  53. 53.0 53.1 Associated Press, "Attorney contests Missouri health insurance ballot," July 14, 2010
  54. Missourian, "UPDATE: Lawyer says insurance measure puts Missouri voters in bind," July 13, 2010
  55. OzarksFirst.com, "Fate of Missouri's Healthcare Ballot in Judge's Hands," accessed July 21, 2010
  56. KTTS 94.7fm, "Missouri Judge Rejects Health Care Block," July 17, 2010
  57. Associated Press, "Judge upholds Missouri health-care ballot measure," July 16, 2010
  58. OzarksFirst.com, "Health Care Opt-Out Vote Will Stay on Ballot," accessed July 21, 2010 (dead link)
  59. OzarksFirst.com, "Judge Upholds Missouri Health Care Vote," accessed July 21, 2010
  60. 60.0 60.1 MissouriNet, "Attorney: opponents to health care ballot measure will not appeal judge’s decision after all (AUDIO)," July 19, 2010
  61. Associated Press, "No appeal on suit against Mo. health care measure," July 20, 2010
  62. KY3 News, "Mo. lieutenant governor promotes federal health care 'opt out' vote, lawsuit," May 26, 2010
  63. Associated Press, "Mo. lt. gov. sues to block federal health care law," July 8, 2010
  64. St. Louis Post-Dispatch, "Peter Kinder files lawsuit challenging U.S. health-care law," July 8, 2010
  65. Fox News, "Obama to Sign Landmark Health Reform Bill," March 23, 2010
  66. CNN, "Obama signs health care reform bill, aims to promote it on the road," March 23, 2010
  67. St. Louis Post-Dispatch, "Poll finds support for Proposition C," July 25, 2010
  68. Associated Press, "Mo. House endorses state constitutional amendment seeking to block health insurance mandates," March 3, 2010 (dead link)
  69. Kansas City Star, "Missouri House sends to Senate plan for voiding federal requirement to buy health insurance," March 16, 2010 (dead link)
  70. FOX2now.com, "Bill Passed In Mo. Could Complicate Health Care Overhaul," March 18, 2010
  71. Associated Press, "Missouri Senate OKs vote on federal health care law," May 4, 2010 (dead link)
  72. Kansas City Star, "Legislation opposing health insurance requirement advances in Missouri," May 4, 2010
  73. Before It's News, "Missouri Joins Health Care Battle," May 7, 2010
  74. Fox News, "State Lawmakers Considering Move to Opt Out of Federal Health Care," June 25, 2009
  75. American Legislative Exchange Council, "ALEC's Freedom of Choice in Health Care Act," accessed July 21, 2010 (dead link)