During the World War II period, the US Supreme Court ruled that

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During World War II, due to wage controls, employers began offering non-wage benefits such as health insurance as a way to attract and retain employees. The US Supreme Court ruled that such benefits could be part of union-management negotiations. However, there was no ruling that health insurance must be employer-based or that all large employers must provide it to their employees. There also wasn't a ruling specifically mandating coverage of major medical expenses during this time.

During the World War II Period, the US Supreme Court