Amend the constitution, or pack the court with liberals. I don't see this court taking kindly to congress trying to create a law that sidesteps their ruling.
As they get more and more radical in their legislation, I see the Congress getting slapped down more and more by the SCOTUS. When the lawsuits over health care "deform" reach the court, I see them being decided against the President and Congress by at least 6-3 margins (I think Breyer will come over to the constitutionalists' side), and maybe even 9-0, after Teh Wun dissed them in the SOTU. But the first shot to be fired may very well be the 2nd Amendment case, because the City of Chicago is one of the litigants. It'll be a subtle jab at Obama and the corrupt machine he came from.