An administrative law judge has ruled that Blue Cross Blue Shield of Michigan has not made the case to raise rates for individuals who buy their own health insurance. The ruling, if upheld by Michigan's Office of Financial and Insurance Services, could lead to smaller rate hikes than the 24% to 42% increases sought by Blue Cross for about 22,000 consumers. It also may have broader implications for businesses and the 4.6 million Michiganders with Blue Cross coverage, given the judge's comments that he found Blue Cross' $2.4 billion in reserves excessive.