# United States v. State of Minnesota (0:26-cv-00273) *Federal Title VII pattern-or-practice action against the State of Minnesota over its statewide affirmative-action hiring program, D. Minn., filed January 14, 2026.* *United States v. State of Minnesota*, No. 0:26-cv-00273, is a civil action that the United States filed against the State of Minnesota in the [[United States District Court for the District of Minnesota]] on January 14, 2026.[^1][^2] The suit is brought under [[Title VII]] of the [[Civil Rights Act of 1964]]. Its complaint alleges that the State's statewide affirmative-action program for its civil service is a pattern or practice of discrimination on the basis of race, color, national origin and sex. That program rests on [[Minn. Stat. § 43A.19]], [[Minn. Stat. § 43A.191]] and Minnesota Rules chapter 3905.[^3] The [[United States Department of Justice]] announced the filing the same day in release No. 26-21, titled *United States Department of Justice Files Lawsuit Against Minnesota's 'Affirmative Action' Regime*. The release stated that Attorney General Pamela Bondi had certified the case as a matter of general public importance.[^4] The Civil Rights Division lists the matter on a case page and hosts a second file that the project's link register identifies as the complaint.[^5][^6] The certification has a procedural effect. Relying on it, the complaint "respectfully invokes its right under 42 U.S.C. § 2000e-6(b) to expedited proceedings" before a three-judge district court.[^7][^8] The release adds that the certification entitles the United States to direct appeal to the Supreme Court.[^4] A three-judge court was designated on January 16, 2026.[^9][^10] The United States filed an amended complaint on September 11, 2026. The last entry in the docket record, dated September 29, 2026, records a change of government counsel, and the docket shows no termination.[^11] The release's title supplies the United States' own term for the State's apparatus: "Minnesota's 'Affirmative Action' Regime." The complaint's facts section is headed "Minnesota's Statutory and Regulatory Affirmative Action Regime."[^4][^12] The U.S. government has used "regime" for governments it opposes. The [[Iraq Liberation Act]] of 1998 (Pub. L. 105-338), for example, states a policy of supporting efforts to remove "the regime headed by Saddam Hussein." The project's catalogue of U.S.-government "regime" usages (*[[How Minnesota Got Here]]*, note 40) finds Minnesota the only U.S. state so described. That is the project's catalogue finding, not an independently established fact.[^13] The complaint states allegations. No order in the docket record through September 29, 2026 decides the merits.[^11] ## Parties and instrument The plaintiff is the United States, suing under Section 707 of Title VII, 42 U.S.C. § 2000e-6. The defendant is the State of Minnesota, which the complaint pleads is a "person" and an "employer" under 42 U.S.C. § 2000e(a) and (b).[^14] The complaint is signed by U.S. Attorney Daniel N. Rosen and Assistant Attorney General Harmeet K. Dhillon, among others, with trial attorney Greta Gieseke as filer.[^15] The civil cover sheet lists Attorney General [[Keith Ellison]] and Assistant Attorney General Nick Pladson as the State's attorneys.[^16] The State was served on January 23, 2026.[^17] The complaint's statutory predicate begins with § 43A.19, subd. 1(a). That provision requires a statewide affirmative-action program for the executive-branch civil service to "eliminate the effects of past and present discrimination, intended or unintended, on the basis of protected group status." It directs the Commissioner of [[Minnesota Management and Budget]] (MMB) to "adopt and periodically revise" the program.[^18] Statewide goals rest on two measures. The first is "the percentage of members of each protected class in the recruiting area population who have the necessary skills." The second is the availability of current employees for promotion or transfer.[^19] Minn. R. 3905.0100 requires "consideration of affirmative action goals on all staffing and personnel decisions." Under Minn. R. 3905.0600, agency heads set numerical goals and timetables for any protected group that a comparison of the unit workforce with the relevant civilian labor force shows to be underutilized.[^12][^20] Section 43A.191, titled *Agency Affirmative Action Programs*, governs executive-branch agencies, and the Commissioner of Management and Budget audits their compliance.[^21] As quoted in the complaint, it contains several requirements: - Each agency must "prepare and implement an agency affirmative action plan." - The Commissioner audits each agency annually and reports to the [[governor]] any agency that fails its requirements for two consecutive years. - Under subd. 3(c), where a protected group is underutilized in a job category, the hiring manager must justify a non-affirmative hire with a Pre-Hire Justification form that "explain[s] the reason for hiring a non-affirmative candidate."[^22] The complaint cites § 43A.191 eight times.[^23] Minn. Stat. § 43A.02, subd. 33, which the complaint quotes, defines the protected groups as "females, persons with disabilities, and members of the following minorities: Black, Hispanic, Asian or Pacific Islander, and American Indian or Alaskan native."[^24] MMB training materials quoted in the complaint call the labor-market benchmark "Final Availability," also known as "What We Should Look Like." That figure is compared with job-category headcounts to determine underutilization.[^25] ## The exhibit: stated purpose and operative terms The complaint attaches the [[Minnesota Department of Human Services]] (DHS) *Hiring Justification* policy ([[DHS Policy 4100.250]]) as Exhibit B. It alleges that the policy "provides an example of how Minnesota discriminates against its employees."[^26] The docket lists the attachment as the DHS Policy.[^2] DHS's Equal Opportunity and Access Division issued the policy on the following dates: - initial date: June 17, 2025 - issue date: July 1, 2025 - effective date: August 12, 2025 Director Andrew Petroski signed it digitally on June 23, 2025. It supersedes DHS administrative policy 4100.005, *Affirmative Action Implementation*, effective May 6, 2014.[^27] The policy states its purpose as "to ensure DHS meets affirmative action responsibilities to comply with state statutes." It adds that DHS "must increase the diversity of its workforce to reflect and effectively serve its client base." It cites Minnesota Statutes chapter 43A and Minnesota Rules chapter 3905 as authority.[^27] The complaint's paragraph 47 renders the second clause as "[to] increase."[^28] The policy's operative terms implement the State's [[Pre-Hire Justification policy]] mechanism: - Hiring supervisors "must provide a hiring justification when seeking to hire a non-underrepresented candidate when hiring for a vacancy in a job category with underrepresentation." - No offer may go to a [[Non-underrepresented candidate]] in such a category before the Equal Opportunity and Access Division approves the justification. - Supervisors must interview at least three underrepresented candidates when the pool contains three or more. - Employees "may be subject to disciplinary action, up to and including termination, for failure to comply with policies."[^29] "Underrepresented" means that a protected group's full-time-equivalent representation is less than its estimated availability in the relevant labor force. Some terms cut the other way. Human Resources informs supervisors whether candidates belong to an underrepresented group, but the list "must not indicate candidates' specific protected group(s)." A justification may rest on objective reasons, including minimum or preferred qualifications, interview scores, references and background checks.[^29] Set side by side, the documents show the following. The complaint quotes the statute's stated aim of making positions "equally accessible to all qualified persons."[^12] The documented mechanism has three parts. It compares workforces numerically by protected group. It requires an approval step only when the selected candidate is outside an underrepresented group. It carries a disciplinary warning for noncompliance.[^29] ## Procedural history - **January 14, 2026.** The complaint is filed with the Attorney General's certification (Ex. A), the DHS policy (Ex. B) and a civil cover sheet. The United States requests a three-judge court.[^2] - **January 16, 2026.** Chief Judge Steven M. Colloton of the [[United States Court of Appeals for the Eighth Circuit]] designates the three-judge court: Circuit Judge [[Raymond W. Gruender]], Chief Judge [[Patrick J. Schiltz]] and Judge [[D. Price Marshall Jr.]] (E.D. Ark.).[^9][^10] The State's counsel appears, and the summons issues.[^30] - **January 17–18, 2026.** The case is assigned to Magistrate Judge Dulce J. Foster, who recuses. It is reassigned to Magistrate Judge Shannon G. Elkins.[^31] - **January 23, 2026.** The State is served; its answer is due February 13.[^17] - **February 4, 2026.** An unopposed extension is granted, making the State's response due February 27.[^32] - **February 27, 2026.** The State moves for a more definite statement, and a hearing is set for April 8.[^33] - **March 5–12, 2026.** The United States opposes the motion, and the State replies by leave of court.[^34] - **April 8, 2026.** A 17-minute hearing is held in Courtroom 9E, [[Minneapolis]]. The motion is taken under advisement.[^35] - **May 26, 2026.** A written order denies the motion.[^36] - **June 16, 2026.** The State answers the complaint.[^37] - **July 27–August 3, 2026.** The parties file a jointly signed Rule 26(f) report, and a Rule 16 pretrial conference is held.[^38] - **August 4, 2026.** A pretrial scheduling order is entered with these deadlines:[^39] - amended pleadings: September 1, 2026 - fact discovery: March 1, 2027 - expert discovery: April 15, 2027 - non-dispositive motions: March 15, 2027 - dispositive motions: July 15, 2027 - **September 1, 2026.** The United States moves to amend the complaint, and a hearing is noticed for October 5.[^40] - **September 9–10, 2026.** The parties stipulate regarding the amended complaint and the State's partial motion to dismiss, a protective order, and discovery preservation. The court enters orders on each.[^41] - **September 11–29, 2026.** The amended complaint is filed, and government counsel changes.[^11] ## Claims Both counts are pleaded as pattern-or-practice claims under Section 707(a).[^42][^43] Count 1 alleges violations of § 703(a)(1), 42 U.S.C. § 2000e-2(a)(1). In the complaint's words: "Because staffing is a zero-sum game, when Minnesota gives preferences to employees or prospective employees because of their race, color, national origin, and sex, it inevitably and necessarily discriminates against other employees or prospective employees because of their race, color, national origin, and sex." The count cites race- and sex-based goals. It also cites the requirement that agencies "justify" and obtain approval before hiring employees who are not female, black, Hispanic, Asian, Pacific Islander, American Indian or Alaskan native.[^42] Count 2 alleges violations of § 703(a)(2). It contends that the § 43A.02 definition of protected groups "is not merely descriptive." According to the complaint, the definition is "incorporated directly into Minnesota's affirmative action mandate," and it imposes additional procedural burdens on candidates outside the designated groups.[^43] The complaint alleges that Minnesota "identifies no prior or present discrimination to justify its race- and sex-conscious employment policies." Instead, it alleges, the State adopted a universal approach "premised on a lack of numerical congruence" between agency workforces and the labor market. On that basis, the complaint argues that the program fails "even under the permissive Weber/Johnson framework," citing *Humphries v. Pulaski County Special School District*, 580 F.3d 688 (8th Cir. 2009).[^44] The complaint also argues that *[[United Steelworkers v. Weber]]*, 443 U.S. 193 (1979), and *Johnson v. Transportation Agency*, 480 U.S. 616 (1987), rested on Title VII's "spirit" rather than its text. It contrasts them with the textualism of *[[Bostock v. Clayton County]]*, 590 U.S. 644 (2020).[^45][^46] The release says the United States argues those precedents are inconsistent with Title VII's text and later caselaw.[^4] It also quotes officials: - Dhillon: "There is no exception that allows discrimination against employees who aren't considered 'underrepresented.'" - Bondi: "Making hiring decisions based on immutable characteristics like race and sex is simple discrimination."[^4] In *[[Ames v. Ohio Department of Youth Services]]*, 605 U.S. 303 (2025), the Supreme Court held that Title VII's disparate-treatment provision "draws no distinctions between majority-group plaintiffs and minority-group plaintiffs." The Court rejected a heightened "background circumstances" rule.[^47] The complaint as filed does not cite *Ames*.[^45] The complaint seeks four forms of relief:[^48] - a declaratory judgment - a permanent injunction against the challenged staffing practices - equitable relief for affected employees and applicants - costs ## State position According to the complaint, Minnesota has expressed that its affirmative-action plans, including the DHS policy, are required by §§ 43A.19 and 43A.191. The complaint says the State describes the plans as "prospective and analysis-driven" and designed to remedy manifest underutilization.[^49] The State's filings in the docket record are its motion for a more definite statement, which was denied, its answer of June 16, 2026, and joint stipulations.[^36][^37][^41] The substance of the answer is not in the record, and this article does not state it. ## Record of the instrument Section 43A.191 remains published by the Revisor of Statutes.[^21] The record also shows that DHS reissued its implementing policy in June–August 2025, superseding a 2014 policy.[^27] The record does not establish the enactment dates, legislative sponsors, parties or signing governors of §§ 43A.19 and 43A.191 or their amendments, and none is stated here. ## Related matters A separate federal action, No. 0:26-cv-02078, was filed in the District of Minnesota on March 30, 2026 under [[Title IX]]. The DOJ announced it in release No. 26-299.[^50][^51] Project dossier notes caption it *United States v. State of Minnesota*, while the project's companion record styles it *United States v. Minnesota Department of Education*, naming the [[Minnesota Department of Education]] and the [[Minnesota State High School League]] as defendants.[^50] Project dossier notes describe the U.S. Departments of Education and Health and Human Services' Minnesota Title IX letter as an agency finding on the preponderance standard, distinct from the complaint.[^52] ## Notes [^1]: U.S. Department of Justice, *Complaint, United States v. State of Minnesota*, No. 0:26-cv-00273 (D. Minn., Jan. 14, 2026), caption and signature date — parties, court, filing date. https://www.justice.gov/crt/media/1423361/dl [^2]: CourtListener (RECAP), *Docket, United States v. State of Minnesota*, No. 0:26-cv-00273, entries #1–#3 (Jan. 14, 2026) — complaint with Ex. A (Attorney General Certification), Ex. B (DHS Policy), civil cover sheet; request for three-judge court. https://www.courtlistener.com/docket/72142517/united-states-v-state-of-minnesota/ [^3]: U.S. Department of Justice, *Complaint*, ¶¶ 12–13 (Jan. 14, 2026) — cites Minn. Stat. § 43A.19 and Minn. R. 3905.0100; alleges a pattern or practice under 42 U.S.C. § 2000e-6(a). https://www.justice.gov/crt/media/1423361/dl [^4]: U.S. Department of Justice, Office of Public Affairs, *United States Department of Justice Files Lawsuit Against Minnesota's 'Affirmative Action' Regime*, Press Release No. 26-21 (Jan. 14, 2026) — release title; certification; three-judge court and direct appeal; quoted statements of Bondi and Dhillon. https://www.justice.gov/opa/pr/united-states-department-justice-files-lawsuit-against-minnesotas-affirmative-action-regime [^5]: U.S. Department of Justice, Civil Rights Division, *United States v. State of Minnesota* (case page) — DOJ listing of the matter. https://www.justice.gov/crt/case/united-states-v-state-minnesota [^6]: U.S. Department of Justice, Civil Rights Division, *Complaint, United States v. State of Minnesota* (No. 0:26-cv-00273, Jan. 14, 2026) — file identified as the complaint in the project's link register. https://www.justice.gov/crt/file/1757896/download [^7]: U.S. Department of Justice, *Complaint*, ¶ 17 (Jan. 14, 2026) — invokes 42 U.S.C. § 2000e-6(b) on the Attorney General's certification. https://www.justice.gov/crt/media/1423361/dl [^8]: Legal Information Institute, *42 U.S.C. § 2000e-6* — text of the pattern-or-practice and expedited three-judge-court provision. https://www.law.cornell.edu/uscode/text/42/2000e-6 [^9]: CourtListener (RECAP), *Docket*, entries #5–#6 (Jan. 16, 2026) — designation of Gruender, Schiltz and Marshall, signed by Chief Judge Steven M. Colloton; initial case assignment. https://www.courtlistener.com/docket/72142517/united-states-v-state-of-minnesota/ [^10]: Civil Rights Litigation Clearinghouse, *United States v. State of Minnesota*, No. 0:26-cv-00273 — three-judge panel of Gruender, Schiltz and Marshall; direct appeal to the Supreme Court. https://clearinghouse.net/case/47712/ [^11]: CourtListener (RECAP), *Docket*, entries #1–#58, including #55–#58 (Sept. 11–29, 2026) — amended complaint; appearances of Louis Whitsett and Brent Skorup; Greta Gieseke's withdrawal; no terminating entry. https://www.courtlistener.com/docket/72142517/united-states-v-state-of-minnesota/ [^12]: U.S. Department of Justice, *Complaint*, ¶ 20 and the heading preceding it (Jan. 14, 2026) — stated purposes of § 43A.19, subd. 1(a); Minn. R. 3905.0100. https://www.justice.gov/crt/media/1423361/dl [^13]: U.S. Congress, *Iraq Liberation Act of 1998*, Pub. L. 105-338 — states a policy of supporting efforts to remove "the regime headed by Saddam Hussein." The Minnesota-only finding is the project's catalogue (How Minnesota Got Here, note 40), not this document. https://www.govinfo.gov/content/pkg/PLAW-105publ338/pdf/PLAW-105publ338.pdf [^14]: U.S. Department of Justice, *Complaint*, ¶¶ 18–19 (Jan. 14, 2026) — plaintiff sues under Section 707; defendant pleaded a "person" and an "employer." https://www.justice.gov/crt/media/1423361/dl [^15]: U.S. Department of Justice, *Complaint*, signature block, p. 17 (Jan. 14, 2026) — signatories including Rosen, Dhillon, Dolin and Gieseke. https://www.justice.gov/crt/media/1423361/dl [^16]: U.S. Department of Justice, *Civil Cover Sheet*, Doc. 1-3 (Jan. 14, 2026) — State's attorneys Keith Ellison and Nick Pladson. https://www.justice.gov/crt/media/1423361/dl [^17]: CourtListener (RECAP), *Docket*, entry #10 (Jan. 23, 2026) — State served Jan. 23, 2026; answer due Feb. 13, 2026. https://www.courtlistener.com/docket/72142517/united-states-v-state-of-minnesota/ [^18]: U.S. Department of Justice, *Complaint*, ¶¶ 12, 23 (Jan. 14, 2026) — § 43A.19, subd. 1(a) purpose and Commissioner's duty. https://www.justice.gov/crt/media/1423361/dl [^19]: U.S. Department of Justice, *Complaint*, ¶ 25 (Jan. 14, 2026) — § 43A.19, subd. 1(b) bases for statewide goals. https://www.justice.gov/crt/media/1423361/dl [^20]: U.S. Department of Justice, *Complaint*, ¶¶ 26–27, 36 (Jan. 14, 2026) — Minn. R. 3905.0600 numerical goals and timetables. https://www.justice.gov/crt/media/1423361/dl [^21]: Minnesota Office of the Revisor of Statutes, *Minn. Stat. § 43A.191, Agency Affirmative Action Programs* — statute governing executive-branch agencies; compliance audited by the Commissioner of Management and Budget. https://www.revisor.mn.gov/statutes/cite/43A.191 [^22]: U.S. Department of Justice, *Complaint*, ¶¶ 33, 37, 41 (Jan. 14, 2026) — § 43A.191, subds. 2(a), 3(a), 3(c). https://www.justice.gov/crt/media/1423361/dl [^23]: U.S. Department of Justice, *Complaint* (Jan. 14, 2026) — cites § 43A.191 eight times (project validation, PIN-02). https://www.justice.gov/crt/media/1423361/dl [^24]: U.S. Department of Justice, *Complaint*, ¶ 29 (Jan. 14, 2026) — Minn. Stat. § 43A.02, subd. 33 definition of protected groups. https://www.justice.gov/crt/media/1423361/dl [^25]: U.S. Department of Justice, *Complaint*, ¶¶ 31–32 (Jan. 14, 2026) — MMB "Final Availability" benchmark. https://www.justice.gov/crt/media/1423361/dl [^26]: U.S. Department of Justice, *Complaint*, ¶ 45 (Jan. 14, 2026) — DHS Policy No. 4100.250 offered as Ex. B. https://www.justice.gov/crt/media/1423361/dl [^27]: Minnesota Department of Human Services, *Hiring Justification*, Policy No. 4100.250 (effective Aug. 12, 2025), pp. 1, 5, filed as Ex. B, Doc. 1-2 — dates, signature, purpose, authority, supersession of policy 4100.005. https://www.justice.gov/crt/media/1423361/dl [^28]: U.S. Department of Justice, *Complaint*, ¶ 47 (Jan. 14, 2026) — complaint's rendering of the policy's purpose clause. https://www.justice.gov/crt/media/1423361/dl [^29]: Minnesota Department of Human Services, *Hiring Justification*, Policy No. 4100.250, pp. 1–4, Ex. B, Doc. 1-2 — policy statement, discipline, definitions, Human Resources and supervisor procedures. https://www.justice.gov/crt/media/1423361/dl [^30]: CourtListener (RECAP), *Docket*, entries #4, #7 (Jan. 16, 2026) — State's appearance; summons issued. https://www.courtlistener.com/docket/72142517/united-states-v-state-of-minnesota/ [^31]: CourtListener (RECAP), *Docket*, entries #8–#9 (Jan. 17–18, 2026) — reassignment; Magistrate Judge Foster's recusal; reassignment to Magistrate Judge Elkins. https://www.courtlistener.com/docket/72142517/united-states-v-state-of-minnesota/ [^32]: CourtListener (RECAP), *Docket*, entries #12–#14 (Feb. 4, 2026) — extension to Feb. 27, 2026. https://www.courtlistener.com/docket/72142517/united-states-v-state-of-minnesota/ [^33]: CourtListener (RECAP), *Docket*, entries #16–#22 (Feb. 27, 2026) — motion for more definite statement; hearing notice. https://www.courtlistener.com/docket/72142517/united-states-v-state-of-minnesota/ [^34]: CourtListener (RECAP), *Docket*, entries #23–#26 (Mar. 5–12, 2026) — opposition; leave for reply; reply. https://www.courtlistener.com/docket/72142517/united-states-v-state-of-minnesota/ [^35]: CourtListener (RECAP), *Docket*, entry #28 (Apr. 8, 2026) — minute entry; motion taken under advisement. https://www.courtlistener.com/docket/72142517/united-states-v-state-of-minnesota/ [^36]: CourtListener (RECAP), *Docket*, entry #34 (May 26, 2026) — order denying the motion for more definite statement. https://www.courtlistener.com/docket/72142517/united-states-v-state-of-minnesota/ [^37]: CourtListener (RECAP), *Docket*, entry #35 (June 16, 2026) — State's answer. https://www.courtlistener.com/docket/72142517/united-states-v-state-of-minnesota/ [^38]: CourtListener (RECAP), *Docket*, entries #38–#39 (July 27–Aug. 3, 2026) — joint Rule 26(f) report; Rule 16 conference. https://www.courtlistener.com/docket/72142517/united-states-v-state-of-minnesota/ [^39]: CourtListener (RECAP), *Docket*, entry #40 (entered Aug. 4, 2026) — pretrial scheduling order deadlines. https://www.courtlistener.com/docket/72142517/united-states-v-state-of-minnesota/ [^40]: CourtListener (RECAP), *Docket*, entries #41–#44 (Sept. 1, 2026) — motion to amend; hearing noticed for Oct. 5, 2026. https://www.courtlistener.com/docket/72142517/united-states-v-state-of-minnesota/ [^41]: CourtListener (RECAP), *Docket*, entries #46–#54 (Sept. 9–10, 2026) — stipulations and orders on the amended complaint and partial motion to dismiss, protective order, and preservation. https://www.courtlistener.com/docket/72142517/united-states-v-state-of-minnesota/ [^42]: U.S. Department of Justice, *Complaint*, ¶¶ 56–63 (Jan. 14, 2026) — Count 1, § 703(a)(1). https://www.justice.gov/crt/media/1423361/dl [^43]: U.S. Department of Justice, *Complaint*, ¶¶ 64–72 (Jan. 14, 2026) — Count 2, § 703(a)(2). https://www.justice.gov/crt/media/1423361/dl [^44]: U.S. Department of Justice, *Complaint*, ¶¶ 54–55 (Jan. 14, 2026) — no identified prior discrimination; *Humphries*. https://www.justice.gov/crt/media/1423361/dl [^45]: U.S. Department of Justice, *Complaint*, ¶¶ 1–11 (Jan. 14, 2026) — *Weber*, *Johnson* and *Bostock* argument; no citation of *Ames* in the complaint. https://www.justice.gov/crt/media/1423361/dl [^46]: Legal Information Institute, *United Steelworkers v. Weber*, 443 U.S. 193 (1979) — opinion text including Rehnquist dissent. https://www.law.cornell.edu/supremecourt/text/443/193 [^47]: Supreme Court of the United States, *Ames v. Ohio Department of Youth Services*, 605 U.S. 303 (2025) — holding on majority-group plaintiffs; rejection of the "background circumstances" rule. https://www.supremecourt.gov/opinions/24pdf/23-1039_c0n2.pdf [^48]: U.S. Department of Justice, *Complaint*, Prayer for Relief (Jan. 14, 2026) — relief sought. https://www.justice.gov/crt/media/1423361/dl [^49]: U.S. Department of Justice, *Complaint*, ¶ 53 (Jan. 14, 2026) — State's expressed position as stated in the complaint. https://www.justice.gov/crt/media/1423361/dl [^50]: U.S. Department of Justice, Civil Rights Division, *Complaint*, No. 0:26-cv-02078 (D. Minn., Mar. 30, 2026) — Title IX complaint. https://www.justice.gov/crt/media/1433251/dl [^51]: U.S. Department of Justice, Office of Public Affairs, Press Release No. 26-299 (2026) — announcement of the Title IX suit. https://www.justice.gov/opa/pr/justice-department-sues-minnesota-protect-girls-sports-and-intimate-spaces [^52]: U.S. Department of Education and U.S. Department of Health and Human Services, Offices for Civil Rights, *Minnesota Title IX findings* — agency letter described in project dossier notes as a preponderance-standard finding. https://www.ed.gov/media/document/ed-hhs-minnesota-title-ix-findings-112441.pdf