The health insurance lobby is laying the groundwork [3] to block federal health care reform by working through think tanks to pass state laws invalidating federally-mandated reforms. Conservative [4] and libertarian [5] think tanks have started encouraging states to amend their constitutions to block federal health reform measures, including a mandate to purchase health insurance. The idea of amending state laws to thwart health care reform originated in Arizona's conservative Goldwater Institute [6], and was picked up by the pro-business American Legislative Exchange Council [7], whose "health care task force" and "free enterprise board" include a substantial number of drug company executives. In Colorado, Jon Caldara [8] of the free-market think tank Independence Institute [9], is drafting language for a ballot initiative [10] that would amend the state's constitution to undo the health care reforms Congress is working to pass. At least 14 similar state plans are in the works around the country.