Jones v. Schneiderman
2012 U.S. Dist. LEXIS 187574
S.D.N.Y.2012Background
- Plaintiffs challenge 1997 New York Unconsolidated Law § 8905-a banning live professional MMA within New York.
- UFC (Zuffa, LLC) and Plaintiffs allege several rights-based claims tied to the ban, including First Amendment expressions (Counts I, VII) and due process/equal protection concerns (Counts IV, V).
- Court limited initial Rule 12(b)(6) review to Counts IV (Equal Protection) and V (Due Process irrationality); the court ultimately grants dismissal of both Counts IV and V under rational-basis review.
- Statute defines a “combative sport” and exempts boxing, wrestling, and certain martial arts; practical effect is a broad prohibition on live professional MMA in New York.
- MMA's evolution (rules tightening, safety measures) occurred after enactment, with widespread regulatory changes in other states and growing national popularity.
- Courts treat rational-basis review as broad deference to legislative judgments in social/economic policy contexts, allowing classifications that plausibly relate to legitimate state interests such as health/safety and public morals.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the ban satisfies rational basis review for Equal Protection and Due Process | MMA is safer now; the law targets health/safety and morals without necessity. | Law had plausible, rational basis in 1997 and remains rational today. | Yes; law satisfies rational basis for both Counts IV and V. |
| Whether changed circumstances can affect rational-basis validity | Changed MMA safety data and rules should undermine rational basis. | Court need not consider changed facts; rational basis stands if plausible at enactment. | Court assumes potential relevance but still finds rational basis today. |
| Whether public-morals concerns provide a rational basis for the ban | Public morals/youth impact were the basis for the ban. | Legislature could rationally rely on public morals and youth protection. | Rational basis supported by public-morals rationale. |
Key Cases Cited
- Beatie v. City of New York, 123 F.3d 707 (2d Cir. 1997) (rational-basis deference in social policy)
- Minnesota v. Clover Leaf Creamery Co., 449 U.S. 456 (U.S. 1981) (rational-basis; not required to prove outcomes match predictions)
- Hayden v. Paterson, 594 F.3d 150 (2d Cir. 2010) (rational-basis review in equal protection)
- Jankowski-Burczyk v. I.N.S., 291 F.3d 172 (2d Cir. 2002) (legislatures have latitude to approximate problems in classifications)
- City of Cleburne v. Cleburne Living Ctr., 473 U.S. 432 (U.S. 1985) (fundamental rights/suspect classifications trigger heightened scrutiny)
- Brown v. Entertainment Merchants Ass’n, 131 S. Ct. 2729 (2011) (public-safety and youth protection as a legitimate state interest)