Wednesday, December 02, 2009

What Can't Congress Make You Do?

The Milwaukee Chapter of the Federalist Society sponsored an interesting talk this past Monday by David Rivkin, a parter with the firm of Baker & Hostetler in DC.

Rivkin's argues that a Congressionally enacted mandate that individuals purchase health insurance would be unconstitutional, i.e., it would be outside the scope of Congress' authority to regulate commerce among the states. As a prescriptive matter, he is certainly right. Descriptively (i.e., would the Court so rule), its not as clear as Rivkin himself concedes.

Nancy Pelosi claims that Congress has an "essentially unlimited" power to regulate health care. This is an extraordinary claim and based on a view of the Commerce authority that says Congress may regulate any local activity if an effect on interstate commerce can be hypothesized.

That is not, however, quite what current doctrine holds. There are certainly cases in which the the Court has upheld Congressional regulation based on a fairly tenuous connection with interstate commerce. In Gonzales v. Raich, for example, the Court held that Congress could prohibit persons from growing marijuana at home for personal use because it is an "economic activity" that, by altering demand, affects the national marijuana market.

But, in two other reason cases, United States v. Lopez and United States v. Morrison, the Court held that Congress could not regulate certain local activities (carrying guns on or near school property and violent acts against women) that are not themselves economic even thought they certainly have an impact on the national economy.

I am not sure that this is a very useful distinction, but let's assume that it - or something like it - is the principle to be applied. Is purchasing insurance economic because it affects demand for a product or is it noneconomic in that it is not an occupation or business or a private activity that - in some sense - substitues for the services or goods provided by an occupation or business? (Or does it by being a form of self insurance?)

The ramifications of permitting Congress to mandate the individual purchase of insurance are matters of concern. As Rivkin puts it, to permit such a mandate, is tantamount to - or uncomfortably close to - the notion that Congress can regulate you because you are "there" and "being there" will necessarily cause an economic footprint that will affect - in some way - interstate markets.

If that is enough to permit Congressional regulation, then why couldn't Congress mandate that everyone join a health club or purchase vegetables or not purchase junk food?

The problem, it seems to me, stems from the Court's use of the Commerce Clause to permit Congress to do things that it is not constitutionally empowered to do. Enacting national health care is an effort to regulate the provision of health care and not commerce among the states (although it will have an impact on that commerce). Once we admit that impact on commerce justifies Congressional regulation, the idea of Congress as a body with limited and enumerated powers begins to fall apart.


illusory tenant said...

Except that with respect to the health care bill's shared responsibility requirement, Speaker Pelosi wasn't invoking the Interstate Commerce Clause, but rather the tax code.

Apparently Sykes doesn't read his own links.

Anonymous said...

At the moment, I cannot think of a thing that the tax code forces the general population to buy.

Where does Pelosi get the idea that she can use the tax code for this purpose?

Anonymous said...

The train long ago left the station. If Congress can prohibit Ollie's Barbeque in Birmingham, Alabama (Katzenbach v. McClung), from discriminating against black people because of the indirect impact on interstate commerce, it can surely regulate health insurance. Lopez and Morrison are not on point. The mere possession of a weapon in a school zone is not commerce. Violence against women is not commerce. The provision of health care and health insurance are huge parts of interstate commerce.

Rick Esenberg said...

Apparently Sykes doesn't read his own links.

My post was on Rivkin's talk. But I don't think that Charlie was making any doctrinal claims. I think he was saying that Pelosi's view of Congressional power is a bad thing.

The tax code doesn't help you unless you structure this as a true income tax provision and it's not. You can't use the tax code as a vehicle to regulate what Congress otherwise lacks the authority to regulate. You could , of course, try to encourage the purchase of insurance through a true income tax, i.e., by providing a credit or deduction for the purchase of insurance but that's not the House bill and there is unliklely to be a politically viable version of that which will work. To be revenue neutral, you'd have to jack up rates and you'd probably have to abandon or substantially modify the mandates on insurers to take all comers and charge a relatively narrow range of premiums.

As for the train leaving the station, it may well have. But I am not sure that any case has ever held that the individual purchase of a thing is commerce such that Congress can make you buy it. If that's commerce, then the Framers' idea that we have a government of limited and enumerated powers is pretty much dead.

illusory tenant said...

"[Sykes] was saying that Pelosi's view of Congressional power is a bad thing."

It's his job. Just take out everything between 'Pelosi' and 'is,' that's all you need to say, if that.

The thing is, there's nothing remarkable about Pelosi's September 16 (quite the scoop, Charlie) press release.

Apart from its narrative of Pawlenty's scampering down from some bluster, which is amusing, but a bit too subtle for the NRO crowd.

But why whip people into a frenzy over nothing. It's irrational. Speaking of the Framers, can you imagine what James Madison would have thought of Sean Hannity?

There's a law review article for you.

OutragedPeople said...

We live in 1984 25 years later.

I've been following this issue since David Rivkin initiated it over the summer (WSJ, WashPo). Even educated people, attorneys and law professors-- our blogger a notable exception--, do not understand the difference between the social security tax and the mandated purchase of health insurance or between the requirement for car insurance and the mandated purchase of health insurance. Such differences are obvious to David Rivkin and others sensitized to government's increasing incursion into our lives, but too subtle for many others and irrelevant to the majority of House members. This is an outcome of our culture's devaluation of intellectual inquiry and cognitive precision. We may well live to regret it.

Using the Commerce Clause as a justification for requiring all citizens to purchase health insurance can lead to far more serious seizures of personal income and property, such as the requirement to purchase a car to shore up the collapsing auto industry. I heard professors denounce this extension of the clause as absurd, but this same outcry was no doubt made in the previous law cases.

illusory tenant said...

Using the Commerce Clause as a justification for requiring all citizens to purchase health insurance ...

Is not the justification Pelosi (or anybody, to my knowledge) has suggested, which is the question this thread purported to address, I believe.

There's little point to Rivkin and Casey arguing against an individual mandate on Commerce Clause grounds when nobody's forwarding that as their primary rationale.

The Commerce Clause is, at best, a second line of defense against constitutional attacks on the contemplated mandate.

For whatever reason, Rivkin and Casey made the Commerce Clause the emphasis of their critique, which is a lot of a red herring.

Anonymous said...

The other issue with enacting individual mandate is that, in addition to stretching the court’s interpretation of the Commerce Clause, the vertical separation of powers between the federal and state governments will become virtually non-existent. The federal government, as David Rivkin is quick to remind us, is a government of limited and enumerated powers. By dipping their hands into state affairs, such as mandating the purchase of health insurance, the federal government is essentially overstepping its boundaries and eliminating the separation of powers designed to keep our nation free and balanced under the Constitution.

David Rivkin has discussed the implications of allowing such grand and unforeseen powers slide into the hands of our federal government, and I notice that some of the comments about this article have touched on this issue as well. As free Americans, are we really alright with the feds having the power to require us to buy a certain type of car, a health club membership, or perhaps a specific style of clothing? I think not. Controlling and maintaining the vertical separation of powers between the federal and state governments is essential to the continuation of a prosperous United States.

David Rivkin discusses this, and other health-care issues in greater detail on his website:

OutragedPeople said...

As I said, 1984 is happening and David Rivkin appears to be Winston Smtih.

In response to illusory tenant, David Rivkin and Lee Casey have focused on the limited, enumerated powers issue. The Pelosi et al and the plethora of self-righteous law professors have been invoking the Commerce Clause. Rivkin and Casey are merely responding to their assertions.

illusory tenant said...

Well, everybody — I hope — has (as they must) focused on the limited and enumerated powers issue, which is just another way of saying, "the Constitution."

And, OutragedPeople, you just got finished saying that Rivkin and Casey "initiated this issue" (the Commerce Clause justification for an individual mandate) and now you're telling me that R&C are "merely responding" to others' assertions.

I think you were right the first time.

bensonhedges said...

The whole argument for this individually-mandated healthcare has been the Commerce Clause, and it is completely and utterly nonsensical. I cannot see how this "universal healthcare" is a "local activity", or how it will have any effect on interstate commerce. Perhaps I am wrong, but the use of the Commerce clause is what is wrong. The Commerce clause does not apply, therefore, Pelosi is not entitled to "essentially unlimited" power to regulate this.

Anonymous said...

I have read some other things that David Rivkin has written, and I think he knows what he is talking about (go figure he is a CONSTITUTIONAL LAWYER). If this individually-mandated insurance goes into effect, then (as Mr. Rivkin pointed out) they can mandate that American citizens buy a car every couple of years. Doesn't that have some effect on interstate commerce, this whole Commerce clause argument is sheer poppycock!

Anonymous said...

Does this mean that if you don't have private insurance that you will automatically be put into in the government option)plan?

It sounds like the pro-choice people are making all your choices.

Anonymous said...

For those reading this blog who have not taken a course in constitutional law, you should understand that Messrs. Rivkin and Casey are advocating a position that is on the far right fringe of what is today considered acceptable constitutional argument. It wouldn't be sanctioned in a court brief, probably, but it wouldn't garner a single vote in the United States Supreme Court. Health care constitutes 16% of our GDP, and the rise in health care costs threatens this country's economic competitiveness. The power to regulate health care includes the power to enact a comprehensive scheme of regulation. Indeed, Casey and Rivkin themselves say that without a universal mandate to purchase health insurance, universal health coverage couldn't be achieved. The argument that individuals have a liberty interest in not purchasing health insurance which is not subject to federal commerce regulation is remarkably similar to the argument advanced in Lochner v. New York that bakers had a liberty interest in being able to work more than 10 hours a day. And, predictably, Rivkin and Casey cite Bailey v. Drexel Furniture, a 1922 case from the Lochner era, which relies on the since-rejected premise that Congress lacks the power under the Commerce Clause to regulate child labor. Just as Congress has the power under the Commerce Clause to regulate wages and hours and child labor, it has the power to enact comprehensive regulation over the 16% of GDP that is comprised by the health care industry. You may think wage and hour legislation, or child labor legislation, unwise as a matter of policy. Many economists argue that minimum wage laws promote youth unemployment. But Congress's power to enact such legislation has long been beyond dispute, and the Lochner era is not coming back any time soon.

illusory tenant said...

Funny thing is, whole-hog, single-payer universal health care would be far more constitutionally palatable than this "bi-partisan compromise" dog's breakfast wending its way through Congress.

OutragedPeople said...

The reason that health care constitutes 16% of the GDP, if, in fact, it does (can you believe ANY numbers from Congress when they can't produce a decent financial report?), is inflated spending due to government programs and CYA medicine resulting from tort law.

What's needed is to understand the problem first (a good business practice related to quality methods) and then institute continuous improvement.

In the case of healthcare reform, Pelosi et al believe the problem is that not everyone has healthcare-- as usual, her overly simplistic mind can't handle much more.

Sen. Coburn made the best case for fixing what is wrong, instead of burdening future generations and adding bureaucratic layers between a patient and a doctor.

Anonymous said...

Anon 2:46

There is a big difference in laws pertaining to how people treat each other and how the government treats you.

Everyone seems to agree that reform is needed but that wasn't a mandate for universal health care. It was a mandate to put a lid on the out of control rising cost of health care and its abuses.

That could be simply done with legislation that prohibits costs to exceed 15% of income rather then all this other nonsense.

Anonymous said...

To whom do David Rivkin and Lee Casey represent the "far right fringe"? Only the far left and out-of-touch law profs. You're entitled to your opinion, but don't extend your view to the universal "everyone." No data, no credibility.

Anonymous said...

Where were all you right-wing blowhards when Congress and President Bush Jr. passed the bill designed to keep the brain-dead womain in Florida "alive"? If you folks are so concerned about the potential abuse of power by Congress, surely all you folks were ready to march on Washington over that idiotic move, weren't you?

OutragedPeople said...

Oh, so typical (yawn). We (constitutional conservatives) are simply discussing the issues, and the lefties start flinging epithets.

We want to engage in meaningful discourse and get called names (double yawn).

illusory tenant said...

"As usual, [Nancy Pelosi's] overly simplistic mind can't handle much more ... We conservatives are simply discussing the issues, and the lefties start flinging epithets."

Hmm. Time for another civility post, Shark?

That's a good question about Terri Schiavo, by the way. She was less an instrumentality of commerce even than a federally mandated investment.

Dad29 said...

Re Schiavo, there are plenty of Federal criminal statutes which mirror or duplicate State criminal statutes. So?

Rick Esenberg said...

IT writes:

"Using the Commerce Clause as a justification for requiring all citizens to purchase health insurance ...

Is not the justification Pelosi (or anybody, to my knowledge) has suggested, which is the question this thread purported to address, I believe."

RME responds:

That's just wrong. Pelosi's press release says that the mandate uses the tax code but justifies Congress' unlimited power to regulate health care on the Commerce power as do many others. If it can't be justified under the Commerce power, it probably can't be done.

First, a flat mandate can't be justified under the taxing authority. It's unclear that the bill can accomplish what it wants (i.e., make young people buy insurance) without such a mandate.

If it imposes a flat tax based on the refusal to purchase, there are potential problems relating to restrictions on direct taxes and the question of whether the tax is really a penalty and whether, if something is a penalty, it can be an exercise of the taxing authority.

As I said before, you could do something through the income tax (say a credit or deduction) but this may not accomplish the desired objective either.

Anon 2:46

I don't think it is at the far right fringe of constitutional anaylyis at all and Rivkin's position would almost certainly get some votes. It might even prevail.

The reason is not that Congress can't regulate health care. It can. But whether it can do so by mandating individuals to purchase insurance is quite another matter. That is arguably a step further than has ever been countenanced.

illusory tenant said...

Rick, Pelosi addresses the individual mandate as a separate issue, a separate provision of the bill. This has been my point from the outset.

Her press release clearly suggests that the power to compel the mandate derives not from the Commerce Clause but from Congress's taxing power.

You've acknowledged as much right here:

If it can't be justified under the Commerce power, it probably can't be done.

Which is a strange claim to make, because Congress can justify all sorts of things through other than the Commerce Clause.

I don't (and haven't) denied the problem of justifying this "tax" on constitutional grounds.*

As a matter of fact I'm with you on the brief that the Commerce Clause doesn't authorize it. So I have no idea what I've said was "just wrong."

But that specific problem — the compelled health insurance purchase — is separable from all of the other activities that take place within the framework of health care transactions, the regulation of which clearly are permissible exercises of the interstate commerce power.

Let's remember this discussion for when and if the health care bill is challenged in court and on what grounds its various provisions are defended.


* Obama says it's not a tax. Now if Obama thinks the individual mandate is authorized by the power to regulate interstate commerce, then you and Sykes need to go after him, not Pelosi, who has claimed nothing particularly remarkable.

George Mitchell said...

Being ignorant, until now, of the arguments advanced by Rivkin,, I did not see much remarkable in Pelosi's statement. Neither she nor many of her colleagues see practical limits on government power. If things reach a point where a constitutional challenge occurs one assumes it would go to the Supreme Court. Could get interesting.

illusory tenant said...

Neither she nor many of her colleagues see practical limits on government power.

I would go further and say that neither she nor any of her colleagues (including Republicans) see practical limits on government power. But hopefully some of them see the constitutional limits.

Rick Esenberg said...

I don't know that Pelosi was making other than a commerce clause argument. She refers to the fact that the penalty imposes on those who don't buy insurance is in "the tax code." But the Senate version, as I understand it, has a straight mandate and there have been all sorts of people trying to say that is withint the commerce power. So it is incorrect to say that nobody has suggested the Commerce power as justification for a mandate. (Indeed, it is not clear that a mandate - as opposed to a tax - could be justified in any other way.)

George Mitchell said...

President Bush arguably signed an unconstitutional act (McCain-Feingold) that was initially upheld. A change in USSC makeup has seen some of its provisions chipped away. President Obama will sign whatever Congress sends him; will the ultimate fate be in the hands of Justice Kennedy?

Anonymous said...

Congress has the power under the Commerce Clause to mandate employers to negotiate with unions. It has the power under the Commerce Clause to mandate minimum wages an employer may pay. It has the power under the Commerce Clause -- not just the Fourteenth Amendment -- to tell Ollie's Barbeque to serve black people. Congress has the power to require employers to purchase workers' compensation insurance, and it surely would have the power to tell those who drive on interstate highways that they must carry automobile insurance; those who may cause accidents in commerce are subject to regulation that requires them to bear some portion of the costs they may create. By the same reasoning, Congress has the power to tell those who might show up in hospital emergency rooms, uninsured, to buy health insurance. The cost of providing health care to the uninsured is huge and growing, is borne by the rest of us, and affects interstate commerce. The power to regulate commerce includes the power to impose individual mandates that are part of a comprehensive scheme of regulation. This is not particularly controversial, and those who dispute it are indeed on the far right fringe of constitutional thought.

Anonymous said...

By the way blogger and con law prof Mike Dorf of Cornell Law School has a good post on FindLaw, "Constitutionality of Health Insurance Reform, Part II: Congressional Power," posted on November 2, in which he explains why Casey and Rivkin are all wet. Among other things he quotes Wickard V. Filburn's statement that "The stimulation of commerce is a use of the regulatory function quite as definitely as prohibitions or restrictions thereon."

OutragedPeople said...

Rivkin and Casey aren't "all wet." This dismissive tone belies a fear that the youth won't be forced into servitude to pay for the healthcare of the nation.

Rivkin made the point in October that a Supreme Court justice maintained that there must be a limiting principle, since, using the Commerce Clause, nearly anything could be justified.

I am not an attorney, but the comparison to auto insurance and health insurance makes no sense. First, auto insurance requirements are mandated by states and not the federal government, and they apply only to persons WHO CHOOSE TO DRIVE CARS, not because they might be in auto accidents. The justification that someone MIGHT be in a hospital emergency room is ridiculous. Moreover, people without insurance are already being cared for in hospitals now, and the burden is being born by those of us who have health insurance.

The Constitution at its core provides LIMITED, ENUMERATED powers to the federal government, and under the 10th amendment, those not specifically enumerated are left to the states. Vertical separation of powere.

Next, you law profs and others who want to burden our youth will be telling them they have to buy auto insurance even if they don't own a car because they someday MIGHT BE DRIVING one.

What's next?

A breathing tax because someday we MIGHT BE POLLUTING AIR by smoking, burning leaves or driving a car?

Anonymous said...

If Congress really want people to buy health insurance, all they have to do is stop requiring hospitals to provide health care to those that will not pay for it.

Isn't this the real problem?

illusory tenant said...

So it is incorrect to say that nobody has suggested the Commerce power as justification for a mandate.

Okay, you got me. Mark Hall did, although he too emphasizes primarily the tax power — my point, again.

But his CC argument is secondary and lacks the required force and amounts to little more than an assertion plus an unconvincing appeal to the Necessary and Proper Clause (which should be renamed the Necessary Necessary and Proper Clause because it's always necessary when your claim of CC reach is ... reaching).

With respect to anon 12:38, it may be that the courts will devise a rationale for approving a federally mandated commercial purchase based on those courts' own prior holdings, but it would be in effect the fabrication of a power not expressly delegated to Congress by the Constitution.

(Indeed, the courts are more legitimately imbued with the power to consecrate an unconstitutional Act of Congress than is Congress to make that particular Act in the first place, but that's still no reason to accept as axiomatic that case law is correct.)

As Hall puts it, the question of Congress's power to regulate health care is a trivial one easily disposed in favor of Congress but for one provision: the individual mandate. And Hall indicates "the only plausible objection is that mandating the purchase of insurance is not the same as regulating its purchase."

But he doesn't engage this objection, which he just allowed was crucial; rather, he proceeds instead to address his opponents' distinguishing regulating insurers from regulating people, but that is not the proper distinction. Hall thus glides past his own crucial distinction without so much as a how-do-you-do.

The most forceful statement of his argument is that the individual mandate "directly affects interstate commerce," not that it is interstate commerce, which might be enough to satisfy some of the second- or fourth-generation interpretive case law, but I don't think it survives the level of scrutiny that must be applied when one is determining whether an Article I enumerated power even exists and in particular one so coercive on the part of the federal government (Super Duper Strict Scrutiny, h/t Arlen Specter).

In any event, the distinction is not between "what" and "who" but rather between what is "in" commerce and what is not. That is, the permissible objects of regulation are only those which are "in" commerce.

Before the mandated purchase takes place, there is no commerce — and therefore nothing in commerce to regulate. It is only by Congress mandating individuals to make commercial transactions that there becomes something in commerce.

So the question presents as, 'Can Congress force a private party to initiate the transaction that will bring into existence the commerce Congress may regulate.' If the answer is yes, then it's not on account of anything the CC says.

An analogy, not perfect, but illustrative: Biology makes no claim to the origin of life; it assumes life, and that is where its study begins, and not before.

illusory tenant said...

As for the Necessary and Proper Clause.

Although it may be necessary under certain circumstances for Congress to somehow initiate the commerce it wishes to then regulate (which it can do by taxing and spending), it has avenues other than forcing — on penalty — private commercial transactions. If there are other ways to accomplish the objective, then this one is by definition not necessary.

For example, Congress can initiate those transactions itself, which is how it was suggested above that single-payer, universal health care could more comfortably conform with constitutional requirements (not to mention satisfy the aspirational goals described in the Preamble).

But even if the individual mandate mechanism was deemed "necessary" according to some necessarily circular reasoning, it also needs to be "proper" and I'm finding it difficult to apply that adjective, in the constitutional context, to the creation of a brand new, clearly unenumerated power of Congress (at least, unenumerated within the Commerce Clause).

So did I pass the Federalist Society entrance exam?

Terrence Berres said...

"So did I pass the Federalist Society entrance exam?"

Christmas gift hint?

illusory tenant said...

A hint for my Secret Sentelle.

OutragedPeople said...

Many thanks to Rick Eisenberg and "illusory tenant" for the illuminating discussion on the commerce clause and taxing authority.

I believe there are two critical issues regarding this legislation: 1) constitutionality of the mandate to purchase insurance, and any penalty resulting from non-compliance, and 2) "the fiscal problem" or affordability.

Either one of these ought to concern members of Congress. While I am not surprised that various representatives ignore the constitutionality problem, the profligate spending to pay for this program (no one really believes the revenue neutral assertion) should relegate this bill to the trash-heap.

Anonymous said...

To anon 2:46:

Although you like to cite court cases, you don't put them in perspective. You may be right that the Lochner era isn't coming back, but the Lochner era wasn't about regulation per se. It was about regulation that went beyond safety, working conditions, public interest, etc. Lochner struck down only the regulation limiting hours in a work-week and hours per day. It explicitly left regulations that protected public safety and the safety of workers in place. Why did it strike down the hour limitations? Because the people who wanted those regulations were union workers who didn't want to have to compete with immigrants who were willing to work longer and harder at their own bakeries. That regulation protected no one... it was just an arbitrary attempt by unions to get an advantage in the marketplace.

As for Bailey, that case comes out of the Lochner era, but you fail to mention that "child labor" wasn't quite then what it is today. Of my grandparents, who grew up at the time of Bailey, only one graduated high school. That was typical at the time. Most only went for 4-8 years of education, at which point they entered the workforce. Things were changing around that time in the perception of childhood, and the laws Bailey struck down were trying to help things along. Regardless, Bailey involves tax issues rather than regulation, and it's a bit of an anomaly even in the Lochner area in some ways.

The point is that despite all the animosity about Lochner and that era, the decision itself seems pretty reasonable given the context. And the context will again be critical in the current health-care debate. It's thus way too early to declare that Constitutional arguments are only on the fringe.

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