On one of the most controversial points in the health care reform legislation -- the individual mandate to purchase insurance -- President Obama, his team, and all those in favor of the legislation scored a significant victory last week when a three-judge panel of the 6th Circuit Court of Appeals upheld the constitutionality of the "mandate" that individuals purchase health insurance coverage. See SixthCircuit_Health Care.pdf. The challenge questioned whether, under the Commerce Clause, Congress could regulate the economic "inactivity" of failure of individuals to buy insurance. The 4th and 11th Circuits also are expected to issue rulings soon on the issue. Ultimately, the Supreme Court likely will address the issue. In the meantime, those on both sides of the issue anxiously await the 4th and 11th Circuit decisions.