Health insurance giant Blue Cross Blue Shield has been quietly working with the conservative, pro-business front group [3], American Legislative Exchange Council [4] (ALEC) to pass legislation that uses the issue of states' rights as a pretext for declaring healthcare reform unconstitutional. ALEC drafted and distributed model legislation [5], currently in the form of a resolution, that would effectively make both a federally-created health insurance exchange and a public health insurance option illegal under the 10th Amendment to the Constitution, which guarantees certain non-specific rights to the states. Joan Gardner, a senior executive at the Blue Cross Blue Shield Association [6], (BCBS' lobbying group) admitted playing a key role in crafting the resolution. Christie Herrera, who directs a health task force at ALEC, reports that insurance industry lobbyists have been working with ALEC to promote it to legislators. The resolution, and amendments closely related to it, have already been introduced in at least half a dozen states. ALEC has been working behind the scenes for months to advance the idea that proposals put forth by President Obama [7] and the Democrats to regulate the insurance industry and enact a public option, violate states' rights [8].