The Wyoming Supreme Court ruled on Tuesday that abortion must remain legal in that state, despite a 2023 law seeking to ban it. The case is known as State v. Johnson.

Wyoming is America’s reddest state — President Donald Trump won Wyoming by 46 points in 2024, a wider margin than in any other state — so it is more than a little surprising that abortion is legal there. It turns out, moreover, that abortion is legal in Wyoming entirely because of a largely performative state constitutional amendment enacted in 2012 to undercut the Affordable Care Act, the landmark health care legislation often referred to as Obamacare.

The legislative fight to enact Obamacare was one of the most contentious, and most partisan, congressional battles of the last several decades. Republican opponents of the law argued, often in hyperbolic terms, that the Affordable Care Act amounted to a “government takeover of health care” that would strip many Americans of their ability to make health care decisions.

In the wake of these attacks on President Barack Obama’s signature legislative accomplishment, Wyoming was one of a few states that enacted state laws or constitutional amendments purporting to protect patient choice. Wyoming’s amendment provides that “each competent adult shall have the right to make his or her own health care decisions.”

These patient choice laws were almost entirely symbolic, at least to the extent that they sought to undercut Obamacare. The US Constitution provides that, when a state law is at odds with an act of Congress, the federal law prevails. So, even if Obamacare did restrict patient choice, and even if a state constitution forbids those restrictions, the federal Affordable Care Act supersedes any state law that conflicts with it.