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Administrative Law Keyed to Seamon
King v. Burwell
Citation:
135 S. Ct. 2480 (2015)Facts
The Affordable Care Act established three major reforms to expand health insurance coverage: (1) guaranteed issue and community rating requirements preventing insurers from denying coverage or charging higher premiums based on health status; (2) an individual mandate requiring people to maintain insurance coverage or pay a penalty; and (3) tax credits to make insurance more affordable for low and middle-income individuals. The Act directed states to establish health insurance exchanges but provided that the federal government would establish “such Exchange” if a state failed to do so. Section 36B of the Internal Revenue Code, added by the ACA, provided tax credits for individuals who purchased insurance through “an Exchange established by the State under [42 U.S.C. § 18031].” The IRS issued a rule interpreting this provision to allow tax credits on both state and federally-established exchanges. The petitioners, who lived in Virginia (a state with a federal exchange), challenged this interpretation, arguing that the plain text of the statute limited tax credits to state exchanges only.
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