Those alarmed over growing federal encroachment on the states and their citizens found a plethora of reasons to condemn Chief Justice John Roberts's 2012 opinion upholding Obamacare. Less noticed was Roberts's practical roadmap for future state resistance to federal overreach. Roberts wrote, "In the typical case we look to the States to defend their prerogatives by adopting ‘the simple expedient of not yielding' to the federal blandishments when they do not want to embrace the federal policies as their own. The States are separate and independent sovereigns. Sometimes they have to act like it."
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