Let Them Play MN v. Walz, 517 F.Supp.3d 870

Background

Plaintiffs are Let Them Play MN (a non-profit) and several anonymous youth athletes, parents, and coaches seeking a preliminary injunction against Minnesota COVID-19 rules for organized youth sports: (1) MDH/EO mask requirement for athletes during play (with limited exceptions) and (2) limits/ discouragement on spectators.
Plaintiffs claim violations of the Equal Protection Clause and Due Process Clause of the Fourteenth Amendment and parallel Minnesota-constitutional claims; they also sought expedited discovery.
The record includes competing expert evidence: Plaintiffs submitted physician affidavits warning masks can increase injury risk during high-exertion contact sports; Defendants submitted public-health evidence linking sports to COVID-19 outbreaks and citing benefits of masks and spectator limits.
The court analyzed applicable standards in light of Jacobson and subsequent cases but applied ordinary equal-protection and due-process frameworks (rational-basis review for the challenged rules).
The court denied the preliminary injunction and denied expedited discovery, concluding Plaintiffs were unlikely to succeed on the merits, failed to show imminent irreparable harm, and did not justify expedited discovery; Eleventh Amendment limits jurisdiction over state-law claims.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Equal Protection — treatment of youth sports vs others	EO/MDH guidance irrationally disfavors youth athletes (masks/spectator limits)	Youth sports differ from adults/professional sports and non-sport activities in relevant respects; measures rationally relate to public-health goals	Court applied rational-basis review; rules have a rational basis given COVID-19 risks and evidence; Plaintiffs unlikely to succeed
Procedural Due Process — MDH guidance/rulemaking	MDH guidance exceeds statutory authority and changes without required rulemaking, depriving Plaintiffs of state-law-created interests without process	Guidance is a generally applicable, legislative-type rule; no individualized adjudication requiring additional process; Eleventh Amendment bars federal enforcement of state-law claims	Plaintiffs failed to identify a protected federal interest; procedural-due-process claim fails; state-law remedies belong in state court
Substantive Due Process — liberty interest to play without masks	Plaintiffs assert right to participate in youth sports unencumbered by masks/spectator limits	No fundamental right is implicated; restrictions are rationally related to legitimate public-health interest	No fundamental right shown; rational-basis review satisfied; substantive-due-process claim unlikely to succeed
Expedited Discovery	Plaintiffs seek fast discovery to probe state intent/policy and develop record	Requests are overbroad, undifferentiated, burdensome; no showing of good cause or spoliation risk	Denied — Plaintiffs did not show necessity or tailored scope for expedited discovery

Key Cases Cited

Jacobson v. Massachusetts, 197 U.S. 11 (1905) (public-health statutes entitled to deference; test for relation to public health)
In re Rutledge, 956 F.3d 1018 (8th Cir. 2020) (applying Jacobson framework in pandemic context)
Roman Catholic Diocese of Brooklyn v. Cuomo, 141 S. Ct. 63 (2020) (Court applied strict scrutiny to COVID restrictions on religious worship)
City of Cleburne v. Cleburne Living Ctr., 473 U.S. 432 (1985) (equal-protection analysis and levels of scrutiny)
Dataphase Sys., Inc. v. C L Sys., Inc., 640 F.2d 109 (8th Cir. 1981) (four-factor preliminary-injunction test)
Winter v. Nat. Res. Def. Council, Inc., 555 U.S. 7 (2008) (preliminary injunction is an extraordinary remedy; irreparable harm requirement)
F.C.C. v. Beach Commc’ns, Inc., 508 U.S. 307 (1993) (rational-basis review affords wide latitude to legislative judgments)
Pennhurst State Sch. & Hosp. v. Halderman, 465 U.S. 89 (1984) (federal courts cannot enjoin state officials to conform to state law)
Ex parte Young, 209 U.S. 123 (1908) (official-capacity suits for prospective injunctive relief against state officers for federal-law violations)
Bi-Metallic Inv. Co. v. State Bd. of Equalization, 239 U.S. 441 (1915) (distinction between legislative rules and adjudication for procedural due process)