Sissel v. United States Department of Health and Human Services
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Sissel v. U.S. Department of Health & Human Services is a case that was decided by the United States Court of Appeals for the District of Columbia Circuit on August 7, 2015.
Case background
The Patient Protection and Affordable Care Act, commonly referred to as the Affordable Care Act and/or Obamacare, contained a mandate requiring most individuals to purchase at least minimum health insurance coverage. If they failed or refused to do so, they were required to pay a tax penalty to the federal government. Matt Sissel was a portrait artist from Iowa City, Iowa, who did not have health insurance.[1]
Sissel did not want to buy health insurance. On July 26, 2010, he filed a complaint in the U.S. District Court for the District of Columbia against the U.S. Department of Health and Human Services, challenging the individual mandate's tax penalty as exceeding Congress' constitutional authority under the Commerce Clause. On June 27, 2012, the United States Supreme Court decided National Federation of Independent Business v. Sebelius, holding that the individual mandate penalty falls within Congress' power to lay and collect taxes.[2] With that, Sissel amended his complaint to assert that the individual mandate penalty was unconstitutional under the Constitution's Origination Clause, which states that revenue-raising bills must originate in the U.S. House of Representatives.[3][4]
The district court dismissed the complaint for failure to state a cause of action, holding:[4]
| “ | Pending before the Court is a facial constitutional challenge to 26 U.S.C. § 5000A, which is the requirement to maintain minimum essential insurance coverage contained in the Patient Protection and Affordable Care Act, as amended. The plaintiff, Matthew Sissel, complains that this minimum coverage provision—commonly referred to as the “individual mandate”—is unconstitutional because Congress lacked the power to enact it under the Commerce Clause of the Constitution, and also because it was passed in violation of the Origination Clause of the Constitution. The defendants, who are the primary government agencies and officials charged with overseeing the implementation of the individual mandate, have moved, under Federal Rule of Civil Procedure 12(b)(6), to dismiss the plaintiff's complaint for failure to state a claim on which relief may be granted. In that motion, the defendants contend that the plaintiff's Commerce Clause arguments are foreclosed by the Supreme Court's decision in National Federation of Independent Business v. Sebelius, ––– U.S. ––––, 132 S.Ct. 2566, 183 L.Ed.2d 450 (2012). The defendants also argue that the plaintiff's Origination Clause allegations fail to state a claim because the individual mandate is neither a “Bill[ ] for raising Revenue” subject to the Origination Clause, nor a bill that originated outside the House of Representatives. For the reasons discussed below, the Court grants the defendants' motion.
... In sum, the Court first holds that the plaintiff's Commerce Clause challenge to the Affordable Care Act's individual mandate is foreclosed as a matter of law by the Supreme Court's decision in NFIB, and thus the plaintiff fails to state a claim under the Commerce Clause. The Court further holds that the individual mandate was not a “Bill[ ] for raising Revenue,” and thus the plaintiff's Origination Clause challenge likewise fails to state a claim upon which relief may be granted. In any event, even if the individual mandate were a “Bill[ ] for raising Revenue,” the Court holds that it was nevertheless an amendment to a bill that “originated in the House of Representatives” and thus was enacted in compliance with the Origination Clause.[5] |
” |
| —Judge Beryl A. Howell | ||
Sissel appealed to the U.S. Court of Appeals for the District of Columbia Circuit.
Outcome
On July 29, 2014, a three-judge panel of the U.S. Court of Appeals for the District of Columbia Circuit—Judges Judith Rogers, Cornelia T. L. Pillard and Robert Leon Wilkins—affirmed the district court's dismissal of Sissel's complaint, holding that the Commerce Clause issue had already been settled by National Federation of Independent Business v. Sebelius (NFIB) and that the law was not subject to the Origination Clause.[6]
| “ | Section 5000A of the Patient Protection and Affordable Care Act, 26 U.S.C. § 5000A, mandates that as of January 2014, non-exempt individuals maintain minimum health care coverage or, with limited exceptions, pay a penalty. Matt Sissel, who is an artist and small-business owner who serves from time to time on active duty with the National Guard, appeals the dismissal of his complaint alleging that the mandate violates the Commerce Clause, U.S. Const. art. I, § 8, cl. 3, and the Origination Clause, U.S. Const. art. I, § 7, cl. 1. We affirm, because his contention that the mandate obligating him to buy government-approved health insurance violates the Commerce Clause fails under the Supreme Court's interpretation of the mandate in National Federation of Independent Business v. Sebelius, ––– U.S. ––––, 132 S.Ct. 2566, 2598, 183 L.Ed.2d 450 (2012) (“NFIB ”), and his contention that the mandate's shared responsibility payment was enacted in violation of the Origination Clause fails under Supreme Court precedent interpreting that Clause.
... Because we conclude that the shared responsibility payment in Section 5000A is not a “Bill[ ] for raising Revenue” within the Supreme Court's accepted meaning of that phrase, and thus was not subject to the Origination Clause, this court has no occasion to determine whether it originated in the House or the Senate. ... In sum, under Supreme Court precedent, the presence of another constitutional power does not suggest that a provision is not a “Bill[ ] for raising Revenue,” and the absence of another constitutional power does not, in itself, suggest that it is. Because the existence of another power is not necessary (or sufficient) to exempt a bill from the Origination Clause, the mere fact that Section 5000A may have been enacted solely pursuant to Congress's taxing power does not compel the conclusion that the entire Affordable Care Act is a “Bill[ ] for raising Revenue” subject to the Origination Clause. Where, as here, the Supreme Court has concluded that a provision's revenue-raising function is incidental to its primary purpose, see NFIB, 132 S.Ct. at 2596, the Origination Clause does not apply. The analysis is not altered by the fact that the shared responsibility payment may in fact generate substantial revenues. In light of the Supreme Court's historical commitment to a narrow construction of the Origination Clause, this court can only hold that the challenged measure—whose primary purpose “plainly” was not to raise revenue, id. at 2596—falls outside the scope of the Clause.[5] |
” |
| —Judge Judith Rogers | ||
Afterward on August 7, 2015, the D.C. Circuit rejected Sissel's request for a hearing by the full bench of judges, known as a rehearing en banc.[7]
Sissel then petitioned the Supreme Court for review. The Court declined to hear the case on January 19, 2016.[8]
See also
External links
- Search Google News for this topic
- United States Court of Appeals for the District of Columbia Circuit, "Sissel v. United States Department of Health & Human Services, On Petition for Rehearing En Banc," (2015)
- United States Court of Appeals for the District of Columbia Circuit, Sissel v. United States Department of Health and Human Service (2014)
- United States District Court for the District of Columbia, Sissel v. United States Department of Health and Human Service (2013)
- SCOTUSblog, "Sissel v. Dep’t of Health & Human Services"
- SCOTUSblog, "U.S. seeks to head off new review of ACA individual"
Footnotes
- ↑ SCOTUSblog, "U.S. seeks to head off new review of ACA individual," December 30, 2015
- ↑ U.S. Supreme Court, National Federation of Independent Business v. Sebelius, decided June 27, 2012
- ↑ United States District Court for the District of Columbia, "Sissel v. United States Department of Health and Human Services, Complaint," filed July 26, 2010
- ↑ 4.0 4.1 United States District Court for the District of Columbia, Sissel v. United States Department of Health and Human Service, decided June 28, 2013
- ↑ 5.0 5.1 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
- ↑ United States Court of Appeals for the District of Columbia Circuit, Sissel v. United States Department of Health and Human Service, decided July 29, 2014
- ↑ United States Court of Appeals for the District of Columbia Circuit, "Sissel v. United States Department of Health & Human Services, On Petition for Rehearing En Banc," August 7, 2015
- ↑ SCOTUSblog, "Case file for Sissel v. Dep’t of Health & Human Services," accessed March 26, 2025
