# Letter to Acting Attorney General Todd Blanche, Department of Justice --- MTN Minneapolis, Minnesota [email protected] May 13, 2026 The Honorable Todd Blanche Acting Attorney General U.S. Department of Justice 950 Pennsylvania Avenue NW Washington, DC 20530 **Re: Consolidation of the Minnesota Federal Docket — Rajender Architecture, §43A.191, Feeding Our Future, EIDBI, Cities Church, and Title IX Referral as One Coordinated Matter Under the Task Force to Eliminate Fraud (E.O. of March 16, 2026)** Dear Acting Attorney General Blanche: I write to identify the Department of Justice's active Minnesota docket — currently spanning the Civil Rights Division's §43A.191 challenge, the U.S. Attorney's Office for the District of Minnesota's Feeding Our Future and EIDBI prosecutions, the Cities Church indictment, and the recently-received Title IX referral from ED and HHS — as one coordinated matter whose proper resolution requires recognizing a single institutional defendant: the University of Minnesota and the affiliate apparatus it credentials, capitalizes, and gives doctrinal cover to. The Department of Justice is the lead Cabinet department for this consolidation. **The Portfolio Issue.** The Department of Justice currently holds at least the following Minnesota matters: United States v. State of Minnesota, 0:25-cv-03798 (D. Minn., filed January 14, 2026), a Title VII challenge to §43A.191 certified under a Certificate of General Public Importance; the Feeding Our Future docket (79 indicted, 63 found guilty, Aimee Bock convicted on all counts March 2025, $5.2M forfeiture ordered, leak-and-restriction litigation ongoing as of April 2026); the EIDBI/Housing Stabilization Services fraud docket (six additional defendants charged December 18, 2025, $20M autism + $5.65M HSS, with new indictments preparing per May 2026 reports); the Cities Church indictment (39 defendants total after Bondi superseding indictment, 18 U.S.C. §241 and §248); and the January 26, 2026 referral from ED OCR and HHS OCR regarding Minnesota's refusal to comply with Title IX. https://www.justice.gov/opa/media/1415681/dl | https://www.justice.gov/usao-mn/cities-church-case-information **The University of Minnesota Origin — Direct.** Minnesota Statute §43A.191 is the codification of the consent decree from **Rajender v. University of Minnesota** (D. Minn. 1980). Judge Miles W. Lord, who entered the consent decree, was a graduate of the University of Minnesota Law School (1948). The University's Office for Equal Opportunity and Affirmative Action (EOAA) — founded by Sandra Williams in 1972, two years before Rajender was filed — produced the institutional template that was accepted by the Department of Health, Education and Welfare in 1976 and distributed to 111 institutions as the federal standard. **The University of Minnesota Law School has produced 78 years of consecutive Minnesota Attorney General succession.** The Herfindahl-Hirschman Index for the Minnesota AG pipeline by years of service is 7,549 — three times the Department of Justice's own threshold for "highly concentrated" markets (2,500). The University of St. Thomas Law School, which opened in 2001 and received ABA accreditation in 2004, has produced zero Minnesota AGs in twenty-five years. https://www.revisor.mn.gov/statutes/cite/43A.191 | https://www.justice.gov/atr/horizontal-merger-guidelines-08192010 | https://www.lrl.mn.gov/mngov/attygen **The Institutional Admissions.** The University of Minnesota's own commissioned Truth Report (April 11, 2023) states that the founding board "committed genocide and ethnic cleansing of Indigenous peoples for financial gain." In October 2025, the University signed an Office for Civil Rights Resolution Agreement acknowledging that its PhD Project partnership **violated Title VI by discriminating against white and Asian students** — a contemporary admission of unlawful conduct exactly five months before the Department referred its Title VI files to DOJ. These two admissions, taken together, are an evidentiary chain spanning 174 years that the institution has produced from its own commissioned and adversarial proceedings. https://mn.gov/indian-affairs/assets/full-report_tcm1193-572488.pdf | https://www.startribune.com/the-u-signs-agreement-acknowledging-discrimination-against-white-and-asian-students-cuts-ties-with-recruiting-nonprofit/601564669 **The Maitland Precedent.** Maitland v. University of Minnesota, 155 F.3d 1013 (8th Cir. 1998), held that the University's continuing application of the Rajender consent decree, applied as a hard preference in subsequent hiring, exceeded what Title VII permitted. The Eighth Circuit found the architecture unlawful in 1998. Minnesota expanded the architecture through five subsequent amendments to §43A.191 over the following twenty-seven years. The §43A.191 challenge now before the District of Minnesota and the Department's certification of general public importance reflect that history of state non-compliance with binding circuit precedent. https://law.justia.com/cases/federal/appellate-courts/F3/155/1013/ **The Operational Predicates.** The Feeding Our Future, EIDBI, Housing Stabilization Services, and the broader $9 billion estimated Medicaid fraud (House Oversight, March 4, 2026) are the operational outputs of the credentialing architecture §43A.191 codifies and the University of Minnesota's affiliated training pipeline produces. The nonprofit-management cohort that operated the Feeding Our Future shells is credentialed predominantly by the University of Minnesota Carlson School. The clinical-evaluator class that produced the fraudulent autism diagnoses driving EIDBI's 700% growth is credentialed by the University of Minnesota Medical School. The Minnesota Department of Education senior staff, which administered the USDA pass-through that funded Feeding Our Future, is credentialed by the University of Minnesota College of Education and Human Development. https://oversight.house.gov/wp-content/uploads/2026/03/The-Cost-of-Doing-Nothing_How-Tim-Walz-and-Keith-Ellison-Fueled-Minnesotas-Fraud-Explosion_3.4.26_FINAL.pdf **The Consolidated Federal Posture.** Vice President Vance's Task Force to Eliminate Fraud is the executive-branch coordinator under the March 16, 2026 Executive Order. The Department of Justice is the lead Cabinet department for the consolidated response. https://www.whitehouse.gov/presidential-actions/2026/03/establishing-the-task-force-to-eliminate-fraud/ **The Ask.** I respectfully request that the Department of Justice: 1. **Treat the Minnesota docket as one matter** under the Civil Rights Division (§43A.191, Title IX referral, Cities Church), the Criminal Division and U.S. Attorney's Office (Feeding Our Future, EIDBI, HSS), and the Antitrust Division (the HHI 7,549 credentialing-concentration question) — coordinated through the Task Force to Eliminate Fraud; 2. **Address the Civil Rights Division's institutional posture** following the January 13, 2026 resignations of twelve-plus federal prosecutors and section chiefs after the Renée Good killing during Operation Metro Surge, so that the consolidation effort is not impeded by the operational disruption at the Division level; 3. **Develop the institutional-defendant theory** in light of the Truth Report (April 11, 2023) and the OCR Resolution Agreement (October 2025), both of which are admissions against interest by the University of Minnesota itself; and 4. **Treat Maitland v. UMN (8th Cir. 1998)** as the controlling precedent that bars further state-court expansion of the Rajender architecture and as the doctrinal foundation for the three-judge-panel review the Department has invoked. This letter is one of approximately twenty Cabinet-level briefings I am submitting under the Task Force framework. The Department of Justice receives the lead-coordination version because the Department holds the federal prosecutorial authority necessary for the consolidation. Respectfully submitted, MTN [email protected] --- **Primary Sources Cited:** - E.O. Task Force to Eliminate Fraud: https://www.whitehouse.gov/presidential-actions/2026/03/establishing-the-task-force-to-eliminate-fraud/ - US v. State of Minnesota Complaint: https://www.justice.gov/opa/media/1415681/dl - Civil Rights Litigation Clearinghouse case page: https://clearinghouse.net/case/47014/ - Minn. Stat. §43A.191: https://www.revisor.mn.gov/statutes/cite/43A.191 - Maitland v. UMN, 155 F.3d 1013 (8th Cir. 1998): https://law.justia.com/cases/federal/appellate-courts/F3/155/1013/ - DOJ Horizontal Merger Guidelines (HHI threshold): https://www.justice.gov/atr/horizontal-merger-guidelines-08192010 - Minnesota AG succession: https://www.lrl.mn.gov/mngov/attygen - Cities Church case page: https://www.justice.gov/usao-mn/cities-church-case-information - Feeding Our Future prosecution coverage: https://www.justice.gov/usao-mn/pr/federal-jury-finds-feeding-our-future-mastermind-and-co-defendant-guilty-250-million - UMN TRUTH Report: https://mn.gov/indian-affairs/assets/full-report_tcm1193-572488.pdf - UMN OCR Resolution Agreement: https://www.startribune.com/the-u-signs-agreement-acknowledging-discrimination-against-white-and-asian-students-cuts-ties-with-recruiting-nonprofit/601564669 - House Oversight Report: https://oversight.house.gov/wp-content/uploads/2026/03/The-Cost-of-Doing-Nothing_How-Tim-Walz-and-Keith-Ellison-Fueled-Minnesotas-Fraud-Explosion_3.4.26_FINAL.pdf - DOJ Civil Rights Division resignations (Jan. 13, 2026): https://www.cbsnews.com/news/minneapolis-ice-agent-shooting-justice-department-civil-rights-division-resignations/ - UMN EOAA: https://eoaa.umn.edu/ #Addresses_Advisories_and_Archives