On March 28, 2019, Judge John D. Bates of the District of Columbia found major provisions of the Department of Labor’s (DOL’s) final rule on association health plans (AHPs) to be unlawful. The rule’s interpretation of “employer” to include working owners and groups without a true commonality of interest was unreasonable and, as Judge Bates put it, “clearly an end-run around the [Affordable Care Act].” The court set aside these parts of the regulation and remanded the rule to the DOL to determine how the rule’s severability provision affects the remaining provisions.