Health care reform On June 28, 2012, Roberts delivered the majority opinion in National Federation of Independent Business v. Sebelius, which upheld the Patient Protection and Affordable Care Act by a 5–4 vote. The Court indicated that although the "individual mandate" component of the Act could not be upheld under the Commerce Clause, the mandate could be construed as a tax and was therefore ruled to be valid under Congress's authority to "lay and collect taxes." The Court overturned a portion of the law related to the withholding of funds from states that did not comply with the expansion of Medicaid; Roberts wrote that "Congress is not free ... to penalize states that choose not to participate in that new program by taking away their existing Medicaid funding." Sources within the Supreme Court state that Roberts switched his vote regarding the individual mandate sometime after an initial vote and that Roberts largely wrote both the majority and minority opinions. This extremely unusual circumstance has also been used to explain why the minority opinion was also unsigned, itself a rare phenomenon from the Supreme Court. LGBT rights In Hollingsworth v. Perry (2013), Roberts wrote the 5–4 majority opinion holding that Petitioners, appealing a lower court ruling that California's Proposition 8 was unconstitutional, lacked standing to sue, with the result that same-sex marriages resumed in California. Roberts dissented in United States v. Windsor in which the 5-4 majority ruled that key parts of the Defense of Marriage Act were unconstitutional. The case stated the federal government must recognize same-sex marriages that have been approved by certain states. He dissented in the Obergefell v. Hodges case in which Kennedy wrote for the majority, again 5–4, that same-sex couples had a right to marry. In Pavan v. Smith, the Supreme Court "summarily overruled" the Arkansas Supreme Court's decision that the state did not have to list same-sex spouses on birth certificates; Clarence Thomas, Samuel Alito, and Neil Gorsuch dissented, but Roberts did not join their dissent, leaving open speculation that he might have ruled with the majority. In the cases of Bostock v. Clayton County, Altitude Express, Inc. v. Zarda, and R.G. & G.R. Harris Funeral Homes Inc. v. Equal Employment Opportunity Commission (2020), heard together, Roberts ruled with the 6–3 majority deciding that businesses cannot discriminate against LGBT people in matters of employment. In October 2020, Roberts joined the justices in an "apparently