California v. Texas

Supreme Court of the United States · 2021 · Constitutional Law

141 S. Ct. 2104 (2021)

Updated July 29, 2026

Constitutional LawArticle IIIstandingtraceabilityredressabilityAffordable Care Actminimum essential coverageunenforceable statutory provision

Facts

The Affordable Care Act originally required most Americans to maintain minimum essential health insurance coverage and imposed a monetary penalty on many who failed to do so. In 2017, Congress amended the statute by setting the penalty amount to $0, effective beginning in tax year 2019. Texas, other States, and two individual plaintiffs sued federal officials, arguing that without the penalty the minimum essential coverage provision in 26 U.S.C. §5000A(a) was unconstitutional and that the rest of the Act was inseverable from it. They sought declaratory relief as to §5000A(a) and broader relief against enforcement of the rest of the Act.

Issue

Did the individual and state plaintiffs have Article III standing to challenge the Affordable Care Act's minimum essential coverage provision after Congress reduced the penalty for noncompliance to $0? More specifically, did they show an injury fairly traceable to defendants' enforcement of the specific provision they attacked and likely to be redressed by the requested relief?

Rule

To establish Article III standing, a plaintiff must allege a personal injury fairly traceable to the defendant's allegedly unlawful conduct and likely to be redressed by the requested relief. An unenforceable statutory provision, standing alone, does not establish traceability or redressability where the plaintiff cannot show any actual or threatened government enforcement of the challenged provision or any remedy that would redress the alleged injury.

🔒

See the holding & full analysis

Create a free KwikCourt account to unlock the rest of this brief — and practice the case.

The court's holding and reasoning
Doctrine tests, pitfalls & exam hypotheticals
10 practice questions + 4 AI-graded essays on this case

Free sample · practice this case

Test yourself

One of 10 multiple-choice questions for this case. Pick an answer to see why.

Congress enacts a federal statute stating that every adult "shall maintain a home emergency kit," but in the same amendment sets the only monetary consequence for noncompliance at $0 and gives no agency any other enforcement authority. After buying supplies in Phoenix, Elena Torres sues the Secretary of a fictional federal preparedness office for a declaration that the command is unconstitutional.

Does Elena have Article III standing?

Explanation. Standing requires an injury fairly traceable to the defendant's allegedly unlawful conduct and likely to be redressed by the requested relief. Where the challenged provision has no means of enforcement, the plaintiff cannot show that any government action caused the plaintiff's costs. The majority also stressed that declaratory relief does not create jurisdiction by itself; without an Article III remedy tied to enforcement, the suit would amount to an advisory opinion.