The District Court for the Middle District of Pennsylvania has declared the minimum essential coverage provision unconstitutional in Goudy-Bachman. More details to follow shortly.
UPDATE: You can access the opinion, written by District Judge Christopher Conner, here. Judge Conner specifically rejected the activity-inactivity distinction, but nonetheless concluded "that the extension of Commerce Clause power to the pre-transaction stage would eliminate 'judicially enforceable boundaries'" on the Commerce Clause. In other words, Congress cannot regulate the pre-transaction practice of not acquiring health coverage as a means to regulating the transaction of obtaining health care services.