District Court Judge Henry E. Hudson, a George W. Bush appointee, has, as expected, ruled the individual mandate unconstitutional. So why are health reformers so unexpectedly pleased?

There are two reasons, but first, let's put this into context. Hudson's ruling is the third from a district court so far. Previously, Judge Norman Moon found the mandate constitutional, and so too did Judge George Steeh. Both Steeh and Norman were Clinton appointees, which is to say that so far, the rulings are proceeding along predictably partisan lines.