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Since the New Deal of the 1930s, the Supreme Court had only twice found Congress exceeded its commerce authority, and never for a program designed to expand the social safety net.
WSJ: Supreme Court Upholds Mandate as Tax
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Obama seems to have been trying to make the accurate observation that since the '30s the court has not struck down a federal law that applies to economic activity on the ground that it exceeds Congress's Commerce Clause authority.
WSJ: The Man Who Knew Too Little
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Roberts firmly rejected the idea that the Commerce Clause gives Congress authority to force citizens to engage in economic behavior, he says.
FORBES: In Losing On Obamacare, Barnett Says, Conservatives Won