King v Burwell (healthcare subsidies case)
📘 King v. Burwell (2015)
✅ Background:
The Affordable Care Act (ACA), often called "Obamacare", required Americans to have health insurance and set up a system of tax credits (subsidies) to help people afford insurance via healthcare exchanges.
The law said subsidies were available for people enrolling "through an Exchange established by the State." But many states didn’t set up exchanges — the federal government did it for them.
⚖️ Legal Question:
Can the federal exchange (HealthCare.gov) legally provide tax subsidies, even though the statute says subsidies apply only to those who purchase insurance “through an Exchange established by the State”?
🧑⚖️ Supreme Court Ruling:
Yes, subsidies are available through both state and federal exchanges.
Decision: 6–3 in favor of the government.
Majority Opinion by Chief Justice Roberts
🔍 Key Legal Reasoning:
The Court used a method of purposive statutory interpretation, not just literal reading.
The phrase “Exchange established by the State” must be read in context of the ACA's purpose — to make insurance affordable nationwide.
If subsidies were denied to users of the federal exchange, the whole system would collapse in states without exchanges — leading to a “death spiral” of insurance markets.
🧠 Legal Principle:
When statutory language is ambiguous and an interpretation would undermine the purpose of the law, courts may interpret it broadly to preserve the law's function.
📚 Related Supreme Court Cases (Explained in Detail)
Here are more than five key cases that tie into King v. Burwell, covering statutory interpretation, healthcare policy, and agency power.
1. NFIB v. Sebelius (2012) – The ACA’s Constitutionality
Facts:
The ACA required individuals to have insurance or pay a penalty (the individual mandate). Plaintiffs argued this was unconstitutional.
Held:
The mandate was constitutional under Congress’s taxing power.
BUT the requirement for states to expand Medicaid was coercive and unconstitutional.
Relation to King v. Burwell:
Both cases are cornerstones of ACA jurisprudence. While NFIB upheld the law’s foundation, King ensured it worked as intended.
2. Chevron v. NRDC (1984) – The Chevron Doctrine
Facts:
The case established a two-step test to determine whether courts should defer to agency interpretations of statutes.
Chevron Test:
Is the statute ambiguous?
If so, is the agency’s interpretation reasonable?
Relation to King v. Burwell:
Although King involved an ambiguous statute, the Court did NOT apply Chevron deference. Instead, it interpreted the statute itself, since the issue had major economic and political importance.
3. FDA v. Brown & Williamson Tobacco Corp. (2000) – Limits on Agency Power
Facts:
The FDA tried to regulate tobacco as a drug.
Held:
The Supreme Court said that Congress hadn’t authorized the FDA to regulate tobacco in that way — despite the agency’s interpretation.
Relation to King v. Burwell:
This case, like King, shows that major policy issues must be decided by Congress, not left to agency interpretation — unless Congress clearly delegates that power.
4. Massachusetts v. EPA (2007) – Climate Policy & Agency Duty
Facts:
Massachusetts sued the EPA for failing to regulate greenhouse gases under the Clean Air Act.
Held:
The EPA must regulate GHGs if they endanger public health.
Relation to King v. Burwell:
Both cases show how courts can require agencies to act consistently with statutory purpose, even in areas of complex policy.
5. Burwell v. Hobby Lobby (2014) – Religious Objections to ACA Mandates
Facts:
A corporation challenged the ACA’s contraception mandate on religious grounds.
Held:
The Court ruled that closely held corporations can opt out of the mandate based on religious belief.
Relation to King v. Burwell:
Both cases involve interpretations of ACA provisions. Hobby Lobby focused on rights vs. mandates, while King focused on access to subsidies.
6. West Virginia v. EPA (2022) – Major Questions Doctrine
Facts:
The case challenged the EPA’s authority to regulate emissions broadly under the Clean Air Act.
Held:
The Court ruled that agencies cannot decide major questions of policy without clear congressional authorization.
Relation to King v. Burwell:
This case further clarified the "major questions doctrine", which influenced the King Court’s decision to decide the statute itself, rather than defer to agency interpretation.
🧠 Summary Table: King v. Burwell and Related Cases
| Case Name | Main Legal Point | Connection to King v. Burwell |
|---|---|---|
| NFIB v. Sebelius (2012) | ACA is constitutional under taxing power | Establishes ACA as valid law |
| Chevron v. NRDC (1984) | Courts defer to agency if statute is ambiguous | King declined to apply Chevron |
| FDA v. Brown & Williamson | Agencies can’t regulate beyond Congress’s intent | Courts decide big questions, not agencies |
| Massachusetts v. EPA (2007) | Agency must act per statutory purpose | Emphasizes proper statutory interpretation |
| Hobby Lobby (2014) | Religious freedom limits ACA mandates | Interprets ACA rights and obligations |
| West Virginia v. EPA (2022) | Major questions require clear congressional authority | Courts, not agencies, decide major policy issues |
⚖️ Final Takeaways from King v. Burwell:
Courts may go beyond the literal text of a statute to preserve its purpose.
Ambiguity in wording doesn’t always favor agency interpretation — especially in major policy areas.
The Affordable Care Act is interpreted in light of its goal: making healthcare accessible and affordable across the U.S.
The major questions doctrine limits administrative power in areas of vast political and economic importance.
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