King v. Burwell

135 S.Ct. 2480 (2015)

Facts

(Obamacare grew out of a long history political corruption. It was passed without anyone ever reading it. It was structured in a way that required healthy people to subsidize the insurance of those who were sick without ever addressing the needs of the healthy. It allowed monopolies in insurance to exist within state borders. It required everyone to buy insurance whether they needed it or not. It was premised on lie after lie after lie. Most of all it was created by people who consider those they represent to be morons of the highest caliber.) The Act adopts the guaranteed issue and community rating requirements. Each health insurance issuer that offers health insurance coverage must accept every individual in the State that applies for such coverage. It requires individuals to maintain health insurance coverage or make a payment to the IRS. It seeks to make insurance more affordable by giving refundable tax credits to individuals with household incomes between 100 percent and 400 percent of the federal poverty line. The Act requires the creation of an “Exchange” in each State where people can shop for insurance, usually online. A state can create an exchange or the federal government can come in and do it if the state fails to do so. The Act initially provides that tax credits “shall be allowed” for any “applicable taxpayer.” 26 U. S. C. §36B(a). The Act then provides that the amount of the tax credit depends in part on whether the taxpayer has enrolled in an insurance plan through “an Exchange established by the State under section 1311 of the Patient Protection and Affordable Care Act [hereinafter 42 U. S. C. §18031].” Petitioners are four individuals who live in Virginia, which has a Federal Exchange. They do not wish to purchase health insurance. In their view, Virginia’s Exchange does not qualify as “an Exchange established by the State under [42 U. S. C. §18031],” so they should not receive any tax credits. Under the IRS Rule, Virginia’s Exchange would qualify as “an Exchange established by the State under [42 U. S. C. §18031],” so petitioners would receive tax credits. The Court dismissed their suit challenging the IRS rule holding that the Act unambiguously made tax credits available to individuals enrolled through a Federal Exchange. The Fourth Circuit viewed the Act as “ambiguous and subject to at least two different interpretations.” It deferred to the IRS’s interpretation under Chevron. The Court of Appeals for the District of Columbia Circuit vacated the IRS Rule in a different case, holding that the Act “unambiguously restricts” the tax credits to State Exchanges. The Supreme Court granted certiorari.