As discussed in the last Washington Update, there were three major cases decided in the Circuit Courts of Appeals in the last few months regarding the individual mandate under the Patient Protection and Affordable Care Act ("PPACA"). Petitions for writs of certiorari from the Supreme Court have been filed by both the petitioners in the 6th Circuit case decided in June 2011 validating the individual mandate [Thomas More Law Center v. Obama, 2011 U.S. App. LEXIS 13265 (6th Cir. June 29, 2011)] and by all parties (26 states and the federal government) in the 11th Circuit case decided in August 2011 striking down the individual mandate [Florida v. United States HHS, 2011 U.S. App. LEXIS 16806 (11th Cir. Aug. 12, 2011)]. Given the Circuit split, this should be a hot topic in the current Supreme Court session that started on October 3.