Let Them Play MN v. Walz, 556 F.Supp.3d 968

Background:

In March 2020 Governor Tim Walz declared a peacetime emergency and issued executive orders restricting activities to limit COVID-19 transmission; several orders regulated youth sports (e.g., EO 20-99 temporary ban, later face-covering and quarantine requirements).
Plaintiffs (Let Them Play MN and individual youth athletes/parents) allege the state biased data collection to exaggerate sports-related COVID risk and challenge (1) the temporary youth-sports ban, (2) mandatory face coverings for youth sports, and (3) quarantine rules applied to youth athletes as violating federal and Minnesota constitutions.
Plaintiffs previously litigated EO 20-99 and were denied a preliminary injunction; they filed this suit and later amended the complaint adding factual allegations.
Defendants moved to dismiss; while the motion was pending the state rescinded the face-covering requirement and, critically, the Minnesota Legislature terminated the peacetime-emergency declaration that provided legal effect to the challenged executive orders.
The district court held many claims barred by the Eleventh Amendment and that, to the extent Eleventh Amendment did not bar relief, Plaintiffs’ claims were moot (no live Article III controversy); the court therefore dismissed the action without prejudice.

Issues:

Issue	Plaintiff's Argument	Defendant's Argument	Held
Eleventh Amendment / suits against state agency and official-capacity monetary relief	Plaintiffs sought damages and sued MDH and state officials to redress constitutional violations	Eleventh Amendment bars suits against state agencies and official-capacity monetary claims; Ex parte Young only allows prospective relief against officers	MDH and official-capacity monetary claims dismissed under Eleventh Amendment; only prospective federal claims survive (but later found moot)
State-law (Minnesota Constitution) claims	Plaintiffs asserted parallel state-constitutional claims	Federal court cannot order state officials to conform to state law (Pennhurst)	Minnesota-constitution claims dismissed for lack of federal jurisdiction
Article III standing / mootness (temporary ban, mask rule, quarantine rules)	Plaintiffs say relief is needed and restrictions may be reimposed; voluntary rescission insufficient to moot claims	Restrictions were rescinded; Legislature terminated the emergency order removing legal effect; government conduct not likely to recur	Claims seeking injunctive/declaratory relief are moot for lack of a live case or controversy; voluntary-cessation exception inapplicable
Equal Protection merits (rational-basis challenge)	Plaintiffs allege irrational, biased treatment of youth sports and discriminatory quarantine enforcement	Restrictions are rationally related to legitimate public-health interests; decisionmakers may rely on reasonable speculation	Even if jurisdiction existed, Plaintiffs failed to plausibly plead similarly situated comparator or that no rational basis exists; equal-protection claim would fail

Key Cases Cited

Pennhurst State Sch. & Hosp. v. Halderman, 465 U.S. 89 (1984) (Eleventh Amendment bars federal suits seeking relief against state governments and agencies)
Ex parte Young, 209 U.S. 123 (1908) (official-capacity suits for prospective injunctive relief permitted to vindicate federal rights)
Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992) (Article III standing elements)
City of Los Angeles v. Lyons, 461 U.S. 95 (1983) (injunctive relief requires ongoing or imminent injury)
Already, LLC v. Nike, Inc., 568 U.S. 85 (2013) (voluntary cessation and mootness principles)
Friends of the Earth, Inc. v. Laidlaw Env't Servs., 528 U.S. 167 (2000) (standard for when voluntary cessation moots a case)
F.C.C. v. Beach Commc'ns, Inc., 508 U.S. 307 (1993) (rational-basis review allows governmental reliance on reasonable speculation)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (plausibility pleading standard)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (plausibility and pleading principles)
City of Cleburne v. Cleburne Living Ctr., 473 U.S. 432 (1985) (equal protection framework)
Jacobson v. Massachusetts, 197 U.S. 11 (1905) (deferential review for public-health regulations)