When the Supreme Court upheld Obamacare's individual mandate last year in National Federation of Independent Business v. Sebelius, it was not a total victory for reform: because the Court held that the Act's Medicaid expansion imposed too coercive a spending condition on states, states were left with a choice whether or not to accept federal money and expand Medicaid to cover individuals up to 133% of the poverty line. The sad and predictable consequence of that latter holding is a large and persistent gap in health care coverage for poor people, as documented in this article in the New York Times, which notes that half the states have not accepted the Medicaid expansion.