MOTION OF IDAHO FREEDOM FOUNDATION, INC.
FOR LEAVE TO FILE AN AMICUS BRIEF
IN SUPPORT OF PLAINTIFFS-APPELLEES
Idaho Freedom Foundation, Inc. (“IFF”) moves for leave to file the accompanying amicus brief in support of Plaintiffs-Appellees. IFF has not yet received written consent of the parties at the time of printing this brief, and IFF respectfully requests that the Court exercise its inherent authority over the docket and allow the filing of the instant brief.
Pursuant to Eleventh Circuit Local Rule 26.1, IFF declares that it is a 501(c)(3) nonprofit public policy research organization that develops and advocates the principles of individual liberty, personal responsibility, private property rights, economic freedom, and limited government. IFF’s mission is to keep Idaho free by generating research and data on key issues, and sharing the findings with opinion leaders, policymakers, media and the citizens of Idaho. IFF states that it has no parent corporation. IFF has issued no stock. IFF certifies that there are no parents, trusts, subsidiaries and/or affiliates of IFF that have issued shares or debt securities to the public.
Pursuant to Fed. R. App. P. 29(c)(5), IFF affirms that no counsel for a party authored this brief in whole or in part and that no person other than IFF and its counsel made a monetary contribution to its preparation or submission.
IFF has an interest in protecting the rights of the people of Idaho individually, as well as the rights of the State of Idaho as a whole. Because Idaho’s standing to participate in this case was explicitly challenged in Defendants’ Brief for Appellants, and because Idaho is the state that will arguably be most dramatically affected by the Patient Protection and Affordable Care Act (the “Act”), IFF has an interest in supporting the Plaintiffs-Appellees in this case. The attached brief addresses Idaho’s claim for standing in this case, and also addresses Idaho’s unique perspective with regard to the Act.
For these reasons, IFF requests leave to file the accompanying amicus brief in the current proceedings.