There are still some other briefs that the Eleventh Circuit has yet to upload in electronic form to PACER, even though they have been filed in hard copy. But here is probably the most significant one: that filed by the Chamber of Commerce's National Litigation Center in support of neither party.
The Chamber makes the same argument it presented last week in the brief it filed at the Fourth Circuit in Virginia v. Sebelius. Namely, it contends that (1) if the minimum coverage provision is unconstitutional, the guaranteed issue and community rating provisions likewise must be declared invalid as unseverable, and (2) several other provisions might be unseverable as well--namely, the risk-adjustment provision, the bar on annual limits for benefits, and the Medical Loss Ratio provision.
You can access the Chamber's brief here.
