King v. Burwell (2014)
- Docket
- 14-114
- Decided
- 2014-01-01
Summary
Question: Did the Internal Revenue Service permissibly create a regulation that extended the tax credits the Affordable Care Act authorized to federal exchanges as well as those created by the states? Conclusion: Yes. Chief Justice John G. Roberts, Jr. delivered the opinion for the 6-3 majority. The Court held that Congress did not delegate the authority to determine whether the tax credits are available through both state-created and federally created exchanges to the Internal Revenue Service, but the language of the statute clearly indicates that Congress intended the tax credits to be available through both types of exchanges. When the plain language of the section in question is considered in the context of the statute as a whole, it is evident that the federally-created exchanges are not meaningfully different from those the states created, and therefore federally-created exchanges are not excluded from the language referring to exchanges created by the states. This reading is also in line with the Congressional intent of covering as many qualified individuals as possible, as the alternative would mean that federally-created exchanges do not contain qualified individuals and operate entirely differently from the state-created ones. Justice Antonin Scalia wrote a dissent in which he argued that that the plain language of the statute clearly limits the tax credits to state-created exchanges. The majority opinion’s attempt to use context to justify a more expansive reading that is at odds with the clear meaning of the text distorts statutory interpretation and amounts to rewriting the statute. Justice Scalia also argued that reading the language of the section in question to refer to both state-created and federally-created exchanges fails to give effect to the times when Congress explicitly chose to conflate the two types of exchanges as opposed to the times it did not. The reading that some parts of the statute refer to both types of exchanges and other parts do not is more consistent with the statute as a whole and gives better effect to Congress’ intent in enacting it. The majority opinion’s use of Congressional intent to support its holding errs by focusing only on one of the goals of the legislation to the exclusion of others, and in doing so oversteps the bounds of its judicial authority. Justice Clarence Thomas and Justice Samuel A. Alito, Jr. joined in the dissent.