In the first court of appeals decision on the PPACA, the Sixth Circuit Court of Appeals upheld the constitutionality of the individual mandate provisions of PPACA. These provisions require most individuals to have health coverage beginning January 1, 2014 or pay a penalty. Thomas Moore Law Ctr. v. Obama, 2011 WL 2556039 (6th Cir. 2011).

The district court had upheld the individual mandate on the following two independent grounds under the Commerce Clause of the Constitution: (1) that it regulates economic activity that substantially affects the interstate health care market; and (2) that it is essential to Congress's larger regulation of the interstate insurance market. The Sixth Circuit Court of Appeals affirmed the district court's decision on both grounds.  

The Fourth Circuit Court of Appeals and the Eleventh Circuit Court of Appeals are also reviewing the constitutionality of PPACA's individual mandate. The constitutionality of the individual mandate is expected to be ultimately addressed by the U.S. Supreme Court.