AMENDMENT XVI
Passed by Congress July 2, 1909. Ratified February 3, 1913.
Note: Article I, section 9, of the Constitution was modified by amendment 16.
The Congress shall have power to lay and collect taxes on incomes, from whatever source derived, without apportionment among the several States, and without regard to any census or enumeration.
The Mulreadys resided in a tidy brick house on a quiet, sloping street in Tenleytown that was lined with old maple trees whose branches arced lazily over the broad lawns fronting each residence. In the sultry haze of a Washington summer, the humidity lay dense enough over the District that not even the most stubborn breeze could squirm its way through the canopy of maple leaves, brilliant green in the gleam of a late afternoon sun. Evie thought it was a bit silly that the sprinklers were on in front of the house, given that it was still hot enough that most of the water was likely to evaporate off the lawn before sundown; but she knew that Chris would give her unrelenting grief for being a tree-hugging conservationist if she said anything too direct, and she knew better than to push him too far on trivial issues at a time like this. Besides, it really was not in the best of taste to critique a person's decisions about their own home, especially when invited over as a guest.
The commotion from around the side of the house indicated that there was already quite a crowd assembled in the backyard, but the Langs opted for the front door, which Louise had assured them would be left unlocked. And, in fact, Louise herself appeared in the kitchen just as Evie was trying to figure out how best to cram a six-pack of beer into the overcrowded refrigerator.
"Evie! Bill!" Louise did her best to give both of her guests hugs without knocking anything off of the counters. "So glad you both could make it."
"Hey, Louise, good to see you," said Evie.
"A replenishment of supplies, as requested," said Bill, offering Louise a grocery bag brimming with packets of hamburger buns. "And thank you for having us, as always."
"You two are lifesavers," Louise beamed. "Oh, goodness, Evie, I can just take those outside and drop them in the cooler there, save you the trouble of having to play Tetris with the stuff in the fridge..."
"And just when I almost had it solved," Evie said in mock lament. "Can I help you bring anything else outside?"
"The buns, I guess, since we were literally about to run out. Oh, and maybe give me three seconds to grab more chips and guacamole."
Bill, sensing that the kitchen was overcrowded with three people trying to maneuver through it, by this point had wandered into the den and was asking Adam about the extremely violent video game that he was playing. Evie glanced out the door of the kitchen and then took a step closer to Louise, who was pouring tortilla chips from a bag into a bowl.
"Everything OK?" she asked gently.
"With me? Absolutely. With Shannon? Better and better every day, thank god; she's hanging out in the backyard with everyone else. With Adam, I have no idea, but everyone tells me that boys his age are just bad at communicating, and he seems normal enough."
"And Chris?" Evie hoped she didn't sound too anxious.
"Oh, fine. Still sulking about work a little, to be honest." Louise shook her head. "I really thought he'd have gotten over that by now."
"Well, given everything that's been going on, I can't really blame him for being upset about things generally; and besides, it's been less than a week since the term ended. Is it too awkward for us to be here?"
"Evie, it's my house and my Fourth of July party, too, and I will be highly offended if you leave just because my husband is displaying less maturity than my teenage son."
"Touché," sighed Evie. "Although, speaking of immature spouses, I think momentarily my husband will be doing his utmost to beat your teenage son at whatever game he's got in there."
"Something horrifically bloody. I don't ask." Louise frowned as she dug through the fridge to find the guacamole. "Did I hear correctly that you might have a case touching on violent video games next term?"
"Yup."
"Can you do something about this?" Louise asked, gesturing in the direction of the den, from which Adam and Bill could be heard debating something animatedly over the sounds of artificial machine gunfire.
"Hmm, I'm not sure it would be wise of me to opine on the potential outcome of a pending case until I've heard all of the arguments."
"Spoken like a true jurist," laughed Louise. "It just bothers me that Adam seems to get so much enjoyment out of, I don't know, running over prostitutes with cars, or gunning crowds of people down with assault weapons. And I fully realize that he's more than intelligent enough to be able to differentiate between a video game and reality, but I can't help it. Was Jake much of a gamer, as a teenager?"
"Not at all. So I imagine Bill's absolutely loving having Adam as a gaming co-conspirator."
Louise shook her head again.
"Well, let's see if we can drag them away from their toys," she said, nudging the fridge shut with one foot as she juggled the chips and guacamole. "Adam? Come outside and be sociable at some point in the near future, will you?"
"Ah, no!" Adam roared in non-response. "How am I at less than 50% health already?"
Evie poked her head into the den, where her husband and Chris's son were seated on opposite ends of the couch, both intently trying to shoot their way through some urban warzone or another.
"Hey," she said to Bill, "you planning to come say hello to everyone?"
"Mmhm," answered Bill, his brow creased in concentration.
Evie leaned against the doorframe, unimpressed.
"Really?"
"Hold on," Bill muttered, his eyes still fixed on the TV screen, "almost... there..."
Something blew up violently on Bill's half of the screen, and Adam whooped victoriously.
"Aw, not fair, she was distracting me," Bill argued, pointing at Evie, who rolled her eyes, dropped the bag of hamburger buns in Bill's lap, and turned to follow after Louise.
"Very mature," she said sarcastically to Bill as he caught up with her. "How old are you, again?"
"About four times the age of the kid who so humiliatingly kicked my ass just now," pouted Bill. "From now on, he's going to refer to me not as 'Chief Justice Lang's Husband', but as 'That Loser I Blew Up in Less Than Three Minutes'."
"Oh, woe is you," answered Evie, letting Bill hold open the back door for her. "Pity you can't take solace in anything like, you know, your Ph.D., or your university tenure, or your international renown in the particle physics world. Also, haven't you told the Mulready kids to call you Bill yet? I know I've certainly told them to call me Evie, although it wouldn't surprise me if Chris still refers to me as 'Chief Justice Lang' in front of them, for the sake of propriety..."
"Of course I have, but you have to understand that the Mulready kids are, for all intents and purposes, part of your legal world," Bill winked. "I'd bet good money that, even if I introduce myself as Bill to everyone at this party, my identity will still remain 'Chief Justice Lang's Husband' to everyone but Chris and Louise."
Evie paused in the dappled shade of an oak tree just off the deck.
"Does that bother you?" she asked.
"I mean, it's not really different from when Jake was younger and everyone at his school knew me as 'Jake Lang's Dad', is it?" Bill shrugged. "I just have to remind myself going into these sorts of contexts that that's who I am around this crowd. It's not an inaccurate description."
"No, but..."
Evie couldn't quite place her finger on what was bothering her. After all, it wasn't like she hadn't been to conferences with Bill at which she was unofficially labeled "Dr. Lang's Wife" for the duration of the weekend. Perhaps it was just strange to know that nowadays, if she turned up on the UMD campus, everyone – including Bill's colleagues and students – would know her instantly as "Chief Justice Lang" without any sort of introduction. Perhaps it was just strange to know that she now had a degree of recognition in her husband's professional world that was completely independent of his standing, and that he did not have an equivalent degree of recognition in hers.
"Stop fretting, Evie," chuckled Bill, as if reading her mind. "I don't mind it, truly. If I did, don't you think I would have started politely bowing out of these sorts of events a long time ago?"
"Fair enough," Evie conceded. "Well, I'm glad to have you here, in any case. You can defend my honor if Chris gets too bellicose."
"Let's hope it doesn't come to that – I can only imagine the scandalous headlines. Are you going to go say hello to him?"
Evie glanced across the lawn, where Chris, a pair of barbecue tongs in one hand, was listening to Evie's old Fourth Circuit colleague Colin McDonnell pontificate about something. In addition to a highly skeptical expression about whatever argument Colin was putting forth, Chris was sporting a bright red apron emblazoned with the words Chef Supreme, a gag gift from some of his former clerks familiar with the Mulreadys' annual Fourth of July barbecue.
"I'll wait until he's free," Evie said. "Here, if you could take care of those buns, I'll drop the beers off over there..."
Shannon Mulready was propped in a deck chair right next to the drinks. Her eyes were closed, which only redirected attention to the fine row of stitches that zigzagged over her right cheekbone and the deep purple bruises that covered that side of her face, but she opened one eyelid halfway as Evie knelt down, opened a cooler, and began shoving cans of beer into the ice.
"I reminded my dad to make the sign that you proposed last year, but I think he willfully forgot," she told Evie, who forced the final can of beer into the least-crowded corner of the cooler and turned around.
"Hey, there," she said to Shannon, shutting the lid. "I thought you were asleep."
"Nah, just resting." The bruise-free half of Shannon's mouth quirked into a smile. "And trying to avoid talking to people."
"I see," said Evie, mildly flattered that she was apparently not considered "people" in Shannon's lexicon. "What sign did I propose your dad make?"
"You don't remember?" Shannon smirked. "For the burger-fixing table: 'Strictly Construct Your Own (Warren E.) Burger Here.' With most of the name in parentheses, of course."
Evie groaned.
"That's basically how Dad reacted when I reminded him."
"I'm embarrassed to have said anything in the first place."
"I happen to like terrible puns," Shannon shrugged. "Would have written out a sign myself, if not for, you know..."
She raised her right arm slightly and let it fall back against her side in its sling. Evie winced involuntarily, then pulled a folding chair a few inches closer to Shannon and sat down.
"I know you're probably sick of people asking this, but how are you doing?"
Shannon shrugged again, this time scowling.
"I guess as fine as anyone ever is with a sprained shoulder, and a broken leg, and a few fractured ribs, and a face that looks like it was mauled by a mountain lion."
"Your dad said the doctors think you'll be more or less back to normal by the end of the summer."
"Thank god for that," grumbled Shannon. "Starting college will be crazy enough, without having to deal with crutches or wheelchairs or what have you."
"You'll be absolutely fine. That's what I keep telling your dad, whenever he starts fussing."
"Oh, Jesus, does he really stress out about me at work?" Shannon huffed in an indignant manner that reminded Evie uncannily of Chris.
"It's just something that happens," she told Shannon, trying to hide her amusement. "We all stress out about our kids at each other. It's an inexhaustible topic of conversation during our lunches, when we're supposed to refrain from discussing cases."
Shannon eyed Evie curiously, opened her mouth as if on the verge of asking something, and then closed it instead. Evie raised her eyebrows.
"I take it the flow of information may run both ways?"
"Well, he's sensible enough not to bore us with the finer details of the law at the dinner table, but it's pretty obvious when something's driving Dad up the wall at work," Shannon explained. "He sort of lives under his own personalized little storm cloud until he's over it, if you know what I mean."
"Yeah."
Evie glanced back over at Chris, who was now flipping burgers on the grill. Even at a distance, the rich aroma of cooking meat mingled tantalizingly with the earthy scent of cut grass.
"You're not avoiding him, are you?" asked Shannon.
"What?"
"Not that I'm not enjoying talking to you, but I'd have expected you to make a beeline over to my dad to say hello, upon arrival. Has he been sulking at the Court, too?"
"I wouldn't say sulking, exactly," Evie replied evasively, figuring that it wouldn't be fair to complain to Chris's daughter that her dad had been steadfastly refusing to acknowledge half of his colleagues ever since she had managed to talk Harry Clark and Rebecca Hoyt around to her side on the taxation issue. "I think he's just been dealing with a lot emotionally."
"Including me." Shannon sighed. "Sorry."
"Oh, goodness, don't apologize, Shannon. You didn't ask to get into an auto accident."
"Try telling my dad that," Shannon grumbled. "I swear, he stood by my bed in the ER and lectured me for a solid 15 minutes about defensive driving, even though I wasn't even the one operating the car at the time."
Evie smiled sympathetically. That sounded exactly like the sort of thing that Chris would do in an attempt to hide a state of complete panic.
"Can I ask you about the case?" Shannon said unexpectedly.
"You haven't discussed it with your dad?"
"I have, but I'm curious to hear your perspective."
"With or without the boring bits about direct versus indirect taxation, and population-based apportionment amongst the States and such?"
"If you want to avoid those bits, I won't complain."
"OK, then." Evie repositioned her folding chair so that the sun wasn't shining right into her eyes through the tree branches, and then turned back to Shannon. "Basically, we were looking at whether or not Congress had had the power to pass the act in the first place. Congress indisputably has power to lay and collect taxes, according to the Constitution. And some of us – not including your dad – looked at the individual mandate requirement and said, well, the Santos Administration is calling it a penalty instead of a tax, but if it walks like a duck and quacks like a duck..."
"But Dad has been grumbling that you're trying to rewrite Article I, or something," Shannon interrupted. "You're not allowed to tell him that I told you that, by the way."
"My lips are sealed," laughed Evie, "although that's nothing he hasn't accused me of trying to do, to my face. So that's the second point on which we disagree. As I mentioned, your dad doesn't think that the individual mandate is a tax; I and a majority of Justices on the Court do. But I also personally think that Congress had the power to enact the individual mandate under other parts of Article I – namely, the Commerce Clause and the Necessary and Proper Clause. The former clause allows Congress to regulate all activity impacted by interstate commerce; your dad thinks that a failure to enroll for health insurance isn't covered by the Commerce Clause because it's technically economic inactivity, which I think is splitting hairs, but he is, of course, entitled to his own opinion. And the latter allows Congress to enact legislation that will help it execute its other Article I powers – creating a national bank, and such, if you've ever heard of McCulloch v. Maryland."
"But how do you get around the fact that the act unfairly penalizes people who don't want to opt into health insurance?" Shannon argued. "That certainly seems like an infringement of individuals' liberty, to charge them for a service they don't need or want."
"Couldn't you make that argument about any tax, though?" Evie answered. "People pay taxes for the maintenance of roads and bridges that they might never use, or for the building and operation of public schools regardless of whether or not they have children attending those schools. They might not want or need those services, but nobody denies that Congress has the right to collect taxes from individuals, for the sake of furthering public interests."
"But if it's not a tax..."
"Then I still think that health insurance impacts interstate commerce to the extent that its regulation falls under the aegis of the Commerce Clause. How could it not? If people don't have access to health care that will ensure that they're treated properly for illnesses and accidents, it'll take an enormous toll on their ability to contribute to the economic productivity of society, within and across state borders. And if the individual mandate doesn't stand – whether a tax or no – then the entire project collapses. Surely the young people who argue that they're healthy and don't need insurance are altruistic enough to be willing to sacrifice some for the sake of ensuring that a wider net of Americans won't suffer needlessly? Especially since not even the youngest and healthiest of people are immune to unexpected emergency room visits that can rack up extremely steep medical bills, without health insurance to help cover the costs," Evie added, glancing at the cast on Shannon's leg.
Shannon shook her head, frowning.
"You did ask for my opinion," Evie reminded her.
"This is true, and thank you," Shannon conceded, stretching slightly in her chair. "By the way, you might be surprised to know that I don't disagree with you on the overall concept of government-provided health care; I just don't approve of the form of delivery rolled out by Congress."
"I think most of the country is with you there, for one reason or another," laughed Evie. "And I promise I won't tell your dad that you're theoretically onboard with the fabled death panels, inter alia."
"Oh, he knows. He's been lamenting that he should have anticipated that sending me to Sidwell Friends would liberal me up."
"Years of Quaker education can do that to a person, although for all he knew, you could have become even more reactionary in protest."
"Maybe. The thing is, Dad's always saying that it's important to listen to other people's perspectives, even if they're wrong. And I just think that some of the less-conservative perspectives I've heard over my years at Sidwell have merit to them. That's all."
Evie nodded slowly, marveling at how Chris's daughter could be so incredibly like him, and yet so markedly different, at the exact same time.
"Like I said earlier, you're going to do wonderfully in college, especially if you go in with that attitude."
"Open to persuasion, you mean?"
"Unafraid to hear the other side out, at the very least." Evie grinned. "You'd be surprised at how terrified some people are about even the possibility of having their minds changed."
"You're not talking about my dad, are you?"
"Oh, absolutely not! Your dad is an excellent listener. I think we both aren't satisfied with our own reasoning until we've heard each other out and can pinpoint exactly why we think our own arguments are better than each other's, if we don't end up agreeing. No, everyone on the Court has made an art of keeping a relatively open mind and being acutely aware of everyone else's concerns. It's the only way to garner a majority, after all, to find commonalities where they exist and to compromise where necessary."
Shannon laughed quietly.
"I've gotten the exact same lecture throughout my life, in one form or another," she told Evie. "Seriously, though, you should go get yourself a burger. A Chief Justice Warren E. Burger, even. Just make my dad remember why he likes butting heads with you, and get him out of whatever funk he's been in, would you?"
Evie shot a glance over her shoulder at the barbecue, which Chris was now monitoring while scrolling through messages on his phone.
"Well, here goes nothing," she sighed. "Good talking with you, Shannon, and best of luck with everything."
"Same to you, Chief," Shannon replied with a grin.
The Chief Justice wondered briefly if she should scold Shannon for not just calling her Evie, but she instead stood and walked across the springy grass to where Chris had just slipped his phone into the pocket of his shorts.
"Hey," Evie said as casually as she could. "Can I request one medium-rare with cheese, or have these ones been on the grill too long?"
Without any verbal response, Chris slid a sizzling burger patty onto half of a bun on a paper plate, and handed it to Evie.
"Thanks." Evie crossed her arms as best she could while holding a plate, and tilted her head in an attempt to read her colleague's inclined face. "How are you doing?"
"Fine," Chris replied curtly, not looking at Evie.
"I was just chatting with Shannon. She seems like she's recovering pretty well."
"I saw."
Chris busied himself with transferring the rest of the burgers onto plates. Evie sighed.
"Is it really going to be like this all summer, Chris? Do you want me to keep my distance until the start of the next term? Because I can do that, but it would be nice to be friends again sooner rather than later."
"Whoever said we weren't friends?" snapped Chris.
"Oh, I'm sorry," Evie shot back, "do friends usually refuse to acknowledge each other in the hallways at work? Do friends avoid taking phone calls or casual drop-ins from each other? Do friends accuse each other of dealing 'a blow to the project of American federalism so vicious that it would make James Madison turn his face away in horror'?"
"It's an absurd overreach of Congressional power!" Chris exploded, causing several guests chatting nearby to turn their heads in alarm. "Does the Tenth Amendment not exist? Does federalism as an overarching structure for our government not exist?"
"It's a tax, plain and simple," Evie argued.
"Why did they take such pains to call it a 'penalty,' then?"
"Politics, no doubt, but the nomenclature doesn't stop the penalty from being what it is. After all, that which we call a rose by any other name would smell as sweet..."
"Don't Ashland at me," Chris scowled, employing the term that he had coined for Evie's habitual quoting of Shakespeare, in emulation of her predecessor. "You can be glib about it, if you want, but I wouldn't be surprised if this bit of judicial hocus-pocus is thrown into the 'Anti-Canon' for the future derision of law students nationwide."
"Yes, because agreeing that Congress has the right to ensure that Americans with pre-existing conditions can afford health coverage is perfectly analogous to upholding racial segregation," Evie retorted, sarcasm dripping from every word. "If they had called the individual mandate a federal tax, would it be as acceptable to you as, say, income tax? Or would you still demand that health care be created by the States, and only by the States?"
"If I felt that the penalty functioned like an actual tax did, then that would be a different story. But I don't, and it doesn't, and your wing of the Court has gone too far in doling out powers to branches of the federal government that have no constitutional right to them."
"My wing of the Court?" Evie repeated. "I don't have a wing of the Court, for heaven's sake. Has this one case made you forget all of the unanimous rulings we've had this term? Or the fact that there were at least two cases in which you and I ended up together on one side of an issue, while Ron and Roberto both were firmly on the other?"
Chris harrumphed.
"Look," Evie sighed, "you know that there's always an equally good chance that you'll be able to argue Harry and Rebecca, or whomever else, over to your view of a case. And you know that the status of health care easily could change. Half of Congress has been clamoring to repeal and replace the act, ever since it was passed, and for all you know, they'll be able to do just that at some point in the near future, and do away with the individual mandate in the process."
"It's still bad precedent," Chris grumbled.
"Well, if history decides to file me away in a category with Roger B. Taney, then so be it. And cheer up, even precedent can be overruled by a future Court, if it becomes clear in the future that a mistake has actually been made. So history ultimately will vindicate you, in the highly unlikely event that you're right and I'm wrong," Evie concluded cheekily.
Chris sniffed haughtily, but he seemed somewhat mollified. Evie watched him for a few moments, amused, as he scraped at something charred to the surface of the grill with his barbecue tongs.
"Any plans to go see the fireworks tonight?"
"And deal with the throngs of rowdy, drunken people on the Mall?" Chris made a face. "Not a chance."
"American patriotism at its finest," Evie teased him. "Jenny's apartment has a fabulous rooftop view, apparently, so we were planning to venture over later this evening. You should come along, if you've cooled down enough to not growl at her or at anyone else who might turn up."
Chris shrugged.
"Depends on how late all of this wraps up, and if Shannon's feeling up to it, and if we can find a way to pull Adam away from his Xbox..."
"Excuses, excuses." Evie gave Chris a searching glance. "I know I asked you this already, but really, how are you doing?"
Chris stared absent-mindedly across the lawn, not really seeing the neighbors and friends assembled under the dappled light cast through the oak trees that ringed his backyard.
"Fine," he repeated. "I guess. As well as you might expect. Still worrying about Shannon more than I should, and I'm sure it's only going to get worse as the summer wraps up."
"Yeah. I won't deny that the parental separation anxiety gets pretty intense. Pity they never seem all that drawn to Georgetown, where we could keep an eye on them easily."
"I just wish she hadn't gotten into such a stupid accident this summer, of all times," Chris said. "I would have been worried enough, as it was, and now..."
"Chris, you know it wasn't her fault that a drunk driver hit her boyfriend's car. It could have happened to anyone, and thankfully she's already on the mend, and will probably be left with nothing more than a few scars to show for the whole experience."
Chris sighed.
"Of course, but it's just one more hypothetical disaster scenario that will keep me awake at night when she's off being an independent young adult. Irrational, I acknowledge, but you know how it is."
Evie nodded.
"I suspect I've been letting familial stress impact my conduct at the Court, as well," Chris added. "Not terribly professional of me."
"It's understandable enough."
"Nevertheless, I probably owe you all an apology. Maybe I should drop by Jenny's tonight, and hope that Rob and Paul and Harry and Rebecca show up, too."
"That would be nice." Evie smiled at him. "It's good to have you back to your usual self."
"Well, as you've reminded me, not only is my daughter still alive and recovering quickly, but there are two other branches of government that can and will keep any instances of judicial tyranny in check."
"Right," Evie agreed, rolling her eyes, "and until they do, the tyranny of the judiciary will ensure that the parents of any other teenage girls who get hit by drunk drivers will also be insured, and thus able to pay for hospital treatments."
The corner of Chris's mouth twitched upwards.
"You should eat that, before it gets cold," he said, gesturing to Evie's burger. "Lettuce and onions and tomatoes are at the table over by the deck."
"Thanks." But rather than leave immediately, Evie stayed for just a moment longer, meeting Chris's smile, affirming that any discord between them was slowly but surely dissipating. "Hey, Happy Fourth. Here's to one more year of the Republic surviving."
"And doing so in spite of our all-too-human flaws," Chris replied, but without any bitterness.
As Evie headed back towards the deck, Bill caught her eye from where he and Louise were now listening politely to one of Chris's Federalist Society friends explain everything wrong with the Court's recent health care ruling. He raised his eyebrows in a silent question, then grinned when Evie flashed him a thumbs-up.
"You look considerably happier," Shannon noted as Evie passed her. "I take it you somehow managed to convince Dad that the world isn't actually ending?"
"I think you could say so, yes."
"Oh, thank goodness. Thank you." Shannon glanced at the plate that Evie was holding. "Off to go strictly construct yourself a burger now?"
"We'll have to see about the strict construction part," Evie winked. "After all, I think I can safely assert that it'll still be a Chief Justice Burger, regardless of my chosen theory of constitutional interpretation, no?"
Shannon shut her eyes in mock dismay.
"I should have seen that one coming," she muttered.
"I thought you said you liked terrible puns."
"Yes, but I'd label that one almost criminally awful."
"Then in the future, I'll exercise my right to remain silent," the Chief Justice quipped cheerfully.
"Worse and worse, Evie," groaned Shannon, waving her uninjured hand. "Better stop while you're ahead, and go doctor your food."
It wasn't until later – sometime after she and Louise had talked Chris into agreeing to watch the fireworks from Jenny's rooftop that evening – that Evie realized that the Mulready kids apparently did call her by her first name. It was a strangely comforting fact, a small reminder that she was enough a part of the fabric of Chris's life, even off the bench, that to try to snip her presence out permanently would cause distress to the overall pattern. Evie had never really worried that any contentious case would leave her friendship with Chris irreparably damaged, but she still was relieved to be reminded that his daughter felt comfortable calling her out on her bad puns; that his son challenged her husband to rounds of video games only moments after saying hello; that his wife knew she could always call and ask the Langs to pick up more hamburger buns en route to the party. Beyond being the Chief Justice and Justice Mulready, they were Evie and Chris, an inextricable and comfortable part of each other's professional narratives and daily lives. And for Evie, this was reassurance enough that any wounds they dealt each other would eventually heal over, with enough time and care.
Author's Note: Yes, I currently am having a lot of VERY intense feelings about the Patient Protection and Affordable Care Act. The central legal debate in the above, over the individual mandate being equivalent to a tax, comes from National Federation of Independent Business v. Sebelius (2012); however, if you want a much more colorful judicial take on the legality of Obamacare, I highly recommend Justice Antonin Scalia's indignant dissent in King v. Burwell (2015), which gifted the American legal community with the phrases "SCOTUScare," "jiggery-pokery," and "pure applesauce." (And the briefly-mentioned violent video games case is inspired by Brown v. Entertainment Merchants Association (2011) - apparently, Justices Stephen Breyer and Elena Kagan actually played some violent video games together, in preparation for oral arguments in the case, and Justice Kagan's account of the experience is pretty hilarious, if you care to look up her interview on the subject.)
