Sen. Orrin Hatch (R-Utah) was quick to praise the Virginia district court's ruling that parts of the healthcare law are unconstitutional.

Hatch, who could face a tough primary challenge in 2012, pointed out he was the first senator to argue publicly that the individual mandate is unconstitutional.

That was one of the sections the Virginia judge struck down. U.S. District Court Judge Henry E. Hudson also struck down “directly dependent provisions” while upholding the rest of the law. The decision marks the first major step in a lawsuit destined for the Supreme Court.

“Today is a great day for liberty,” Hatch said in his statement. “Congress must obey the Constitution rather than make it up as we go along. Liberty requires limits on government, and today those limits have been upheld.”

In the 1990s, Hatch actually supported a bill that would have required the individual mandate as part of an effort to kill the Clinton healthcare reform. His office has said since that time, Hatch has examined the constitutionality of the issue and now sees it as unconstitutional.

Hatch also signed a friend-of-the-court brief in regards to another lawsuit against the healthcare law. This suit will be heard Dec. 16 in Florida. 

The six-term Utah senator might not be the only one looking to 2012.

The Virginia lawsuit was brought by Republican state Attorney General Ken Cuccinelli, who is a rising GOP star in the state and mentioned as a 2012 Senate candidate. 

— Jason Millman and Mike Lillis contributed to this post.