St. Louis Effort For AIDS v. Huff, No. 14-1520 (8th Cir. 2015)
Annotate this CaseThe Patient Protection and Affordable Care Act (ACA) creates “navigators,” to assist consumers in purchasing health insurance from exchanges, 42 U.S.C. 18031(i), and authorizes the Department of Health and Human Services to establish standards for navigators and exchanges. HHS regulations recognize: federal navigators, certified application counselors (CACs), and non-navigator assistance personnel. They conduct many of the same activities, but federal navigators have more extensive duties. Plaintiffs, federally-certified counselor designated organizations, employ CACs. The federal government established a Missouri Federally Facilitated Exchange. The Health Insurance Marketplace Innovation Act (HIMIA), Mo. Rev. Stat. 376.2000, regulates “person[s] that, for compensation, provide[] information or services in connection with eligibility, enrollment, or program specifications of any health benefit exchange.” Regulatory provisions dictate what state navigators and cannot do. Plaintiffs challenged: the definition of state navigators; three substantive provisions; and penalty provisions. The district court granted a preliminary injunction, finding that the ACA preempted HIMIA. The Eighth Circuit affirmed in part, finding likelihood of success in challenges to HIMIA requirements that: state navigators refrain from providing information about health insurance plans not offered by the exchange; that in some circumstances, the navigator must advise consultation with a licensed insurance producer regarding private coverage; and that CACs provide information about different health insurance plans and clarify the distinctions. The court vacated the preliminary injunction, holding that ACA does not entirely preempt HIMIA.
Court Description: Civil case - Missouri Health Insurance Marketplace Innovation Act. Where the district court enjoined any attempt by Missouri under its Health Insurance and Marketplace Innovation Act (Mo. Rev. Stat. Sec 376.2000 et seq)to regulate the certified application counselors created by the Affordable Care Act (ACA) to assist in the enrollment of applicants under the ACA, the district court ignored the limited preemption effect created by Sec. 18041(d) of the ACA and should have issued a more limited injunction enjoining only certain portions of the Missouri statute; the district court's injunction is limited to Mo. Rev. Stat. Sections 376.2002.(3),(5) and 376.2008; Section 376.2010.1 - the Missouri Act's remedial provision - did not implicate the plaintiffs' First Amendment rights and the section should not be enjoined.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.