Family Research Council

No. 11-393 and 11-400

In the Supreme Court of the United States

National Federation of Independent Business, et. al.,


Kathleen Sebelius, Secretary of Health and Human Services, et. al.,

State of Florida, et. al.,


Department of Health and Human Services, et. al.,

On Writs of Certiorari to the United States Court of Appeals for the Eleventh Circuit

Brief of the Family Research Council and 27 Members of the U.S. House of Representatives as Amici Curiae in support of petitioners and reversal on the issue of severability


The Family Research Council ("FRC") is a 501(c)(3) nonprofit public-policy organization headquartered in Washington, D.C., which exists to develop and analyze governmental policies that affect families in the United States. Founded in 1983, FRC advocates policy enactments that protect and strengthen family rights and autonomy, and assists in legal challenges of governmental actions detrimental to family interests.

Various provisions of the Patient Protection and Affordable Care Act are contrary to family interests. These provisions--and regulations enacted pursuant thereto--impair family autonomy regarding health care choices, coerce individual decisionmaking, fund abortions, and make health care less affordable for families. These interests are central to FRC's mission, and will be fully vindicated only by holding the Act unconstitutional in its entirety.

Remaining amici curiae are Members of the House of Representatives in the United States Congress seeking complete invalidation of the Act, each of whom represents constituents whose interests are implicated by the issues presented in this case. Those Members are listed alphabetically in the Appendix to this brief.

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