This document is a memorandum opinion regarding a lawsuit that was filed by the State of New York, et. al. on July 26, 2018 against the U.S. Department of Labor. The lawsuit challenges a U.S. Department of Labor final rule that—the plaintiff alleges—upends a decades-old understanding of a foundational employee benefits law for the purpose of exempting a significant portion of the health insurance market from the Affordable Care Act's consumer protections . . .