WASHINGTON, D.C. - Plaintiffs cannot squeeze the individual insurance mandate in the Patient Protection and Affordable Care Act (ACA) into an "arbitrary as-applied" exemption to Congress' taxing power, a panel of the District of Columbia Circuit U.S. Court of Appeals affirmed March 7 (Association of American Physicians & Surgeons Inc., et al. v. Kathleen G. Sebelius, et al., No. 13-5003, D.C. Cir.).