Minnesota Deer Farmers Association v. State of Minnesota, The

U.S. District Court, District of Minnesota

Minnesota Deer Farmers Association v. State of Minnesota, The

Trial Court Opinion

                   UNITED STATES DISTRICT COURT                          
                      DISTRICT OF MINNESOTA                              

MINNESOTA DEER FARMERS                Civil No. 23-3907 (JRT/LIB)        
ASSOCIATION, et al.,                                                     

                       Plaintiffs,  MEMORANDUM OPINION AND               
                                   ORDER GRANTING DEFENDANTS’            
v.                                    MOTION TO DISMISS AND              
                                    DENYING PLAINTIFFS’ MOTION           
SARAH STROMMEN, in her official     FOR PRELIMINARY INJUNCTION           
capacity as Commissioner of the                                          
Minnesota Department of Natural                                          
Resources, et al.,                                                       

                      Defendants.                                        

    Erick  G.  Kaardal  and  Gregory  M.  Erickson,  MOHRMAN,  KAARDAL  & 
    ERICKSON, P.A., 150 South Fifth Street, Suite 3100, Minneapolis, MN 55402, 
    for Plaintiffs.                                                      

    Philip Pulitzer, MINNESOTA ATTORNEY GENERAL’S OFFICE, 445 Minnesota  
    Street, Suite 900, Saint Paul, MN 55101, for Defendants.             

    In 2023, the Minnesota legislature passed legislation intended to combat the 
spread of Chronic Wasting Disease (“CWD”), an illness found in white-tailed deer that is 
incurable, fatal, and potentially transmissible to humans.  The legislation, among other 
changes, increases regulatory oversight of white-tail deer farms and vests that oversight 
with the Minnesota Department of Natural Resources (“DNR”), requires the farmers to 
erect fences to prevent exposure to wild deer, restricts the transfer of white-tail deer 
farm registrations, and prohibits the issuance of new white-tail deer farm registrations.   
    The Minnesota Deer Farmers Association, a Minnesota nonprofit corporation that 
advocates on behalf of deer farmers, and the deer farmers themselves (collectively 

“Plaintiffs”),  brought  this  action  against  DNR  Commissioner  Strommen  and  several 
Minnesota Board of Animal Health (“BAH”) board members in their official capacities 
(collectively “Defendants”), claiming that the legislation violates their due process and 
equal protection rights under the Fourteenth Amendment and their Fifth Amendment 

right  to  be  free  from  unconstitutional  property  seizures.    Plaintiffs  also  request  a 
preliminary injunction enjoining enforcement of Minnesota Statute § 35.155, subdivision 
10(c), and the additional exclusionary fencing requirements.              

    The State enacted § 35.155 to address CWD, a growing health concern that experts 
say could develop into a public health crisis if left unmanaged, which is certainly a 
legitimate state interest that passes rational-basis review.  Plaintiffs thus fail to plead a 
cognizable claim under the Due Process Clause or the Equal Protection Clause.  Plaintiffs 

Fifth Amendment Takings Clause claim also fails as a matter of law.  Accordingly, the Court 
will grant Defendants’ Motion to Dismiss and will deny Plaintiffs’ Motion for Preliminary 
Injunction as moot.                                                       
                          BACKGROUND                                     

    White-tail deer are part of the farmed Cervidae family, which also include mule 
deer, red deer, elk, moose, caribou, and sika.  (Am. Compl. (“Compl.”) ¶ 217, Feb. 12, 
2024,  Docket  No.  12.)    Cervidae  are  susceptible  to  CWD,  an  incurable,  infectious, 
neurological disease of the Cervidae family.1  If a Cervidae, like a white-tailed deer, is 
infected with CWD, the animal’s brain cells deteriorate to a spongy consistency, causing 

the animal to eventually die.  (Compl. ¶¶ 215, 220–21; Mem. Supp. Mot. Prelim. Inj. at 5, 
Feb. 23, 2024, Docket No. 20.)                                            
    Although CWD has previously been considered only a threat to Cervidae, studies 
have recently opined that it may be transmissible to humans.2  Due to this concern and 

the disease’s spread throughout the United States, including into Minnesota, the State 
passed Minnesota Laws 2023, Chapter 60, Article 7, Sections 1–14 (codified at 
Minn. Stat. § 35.155
) to contain and stop the transmission of CWD.3  (Compl. ¶¶ 218–19, 222.) 

    Minnesota has historically regulated the white-tail deer farming industry heavily.  
Section  35.155  continues  to  tighten  regulations,  largely  due  to  the  Minnesota 
Department of Natural Resources 2022 Legislative Report (“Report”), which identified 
farmed Cervidae as a major culprit in introducing CWD to Minnesota.4  The Report also 

noted the hefty cost of CWD surveillance and regulatory oversight of deer farms.5   As a 


    1 Minnesota Dep’t of Nat. Res., Report: Concurrent Authority Regulating Farmed White-
tailed Deer 5 (Feb. 1, 2022), https://files.dnr.state.mn.us/aboutdnr/reports/legislative/2022/con 
current-authority-legislative-report-farmed-deer.pdf.                     
    2 Chronic Wasting Disease, CDC (Apr. 17, 2024), https://www.cdc.gov/chronic-wasting.  
The Court will take judicial notice of CWD’s exposure risks, as detailed on the CDC’s website.  Fed. 
R. Evid. 201(c)(1); see Missourians for Fiscal Accountability v. Klahr, 
830 F.3d 789, 793
 (8th Cir. 
2016) (recognizing authority to take judicial notice of government websites).   
    3 Minnesota Dep’t of Nat. Res., supra note 1 at 5.                   
    4 Id. at 2–3.                                                        
    5 Id. at 6 (noting that the State spent $55,176 on CWD testing in farmed Cervidae and $2.9 
million on CWD activities for wild deer).                                 
result of their findings, the DNR and BAH recommended greater regulation of deer farms 
and heightened fencing requirements.6  The Minnesota Legislature heeded the agencies’ 

recommendations, introducing new and amending existing farmed Cervidae regulations.  
See 
Minn. Stat. § 35.155
.  The subdivisions at issue include:             
    Subdivision 4 details fencing requirements for Farmed Cervidae.      
    Subdivision 10 requires a registration to possess Cervidae, prohibits the State from 

    issuing  new  registrations  to  possess  white-tailed  deer,  and  limits  current 
    registration holders to a one-time transfer to an immediate family member. 
    Subdivision 11(d)(3), upon CWD detection, requires maintaining a fence on the 

    premises for ten years.                                              
    Subdivision 11(d)(5) prohibits raising farmed Cervidae on the premises for ten 
    years upon CWD detection.                                            
    Subdivisions 11(d)(6), upon CWD detection, requires disclosing to a property 

    buyer the date of herd depopulation and the requirements incumbent upon the 
    premises.                                                            
    Subdivision  11(d)(7),  upon  CWD  detection,  mandates  recording  with  the 
    applicable county recorder “the date of detection, the date of depopulation, the 

    landowner  requirements  under  this  paragraph,  and  any  other  information 



    6 
Id.
 at 7–8.                                                        
    required by the board . . . The notice expires and has no effect ten years after the 
    date of detection stated in the notice.”                             

Minn. Stat. § 35.155
 subds. 4, 10–11.                                     

    While Defendant Commissioner Strommen leads the DNR and is charged with 
overseeing, enforcing, and implementing Minnesota Statute § 35.155, the Commissioner 
may contract with the BAH to administer such provisions.  See 
Minn. Stat. § 35.155
 subd. 
15(a).                                                                    
    Plaintiffs allege that (1) § 35.155, subd. 10(c) violates their substantive due process 
rights  under  the  Fourteenth  Amendment  because  it  deprives  Plaintiffs  of  their 

fundamental right to pursue a common calling as white-tailed deer farmers; (2) § 35.155, 
subd. 10(c) violates their right to equal protection under the Fourteenth Amendment by 
advantaging  those  with  immediate  family  over  those  without  and  by  treating  deer 
farmers more stringently than other livestock farmers; (3) § 35.155, subds. 4, 10, and 11 

violate the Takings Clause of the Fifth Amendment; and (4) the DNR’s additional fencing 
requirement violates due process protection because it was implemented without any 
rule-making process.  (Compl. ¶¶ 229–329.)  Additionally, Plaintiffs seek injunctive relief 
against the enforcement of Minnesota Statute § 35.155 subdivision 10(c).  (Id. pp. 63–64.) 
                           DISCUSSION                                    
I.   MOTION TO DISMISS                                                    
    A.   Standard of review                                              

    In reviewing a motion to dismiss under Federal Rule of Civil Procedure 12(b)(6), the 
Court considers all facts alleged in the Complaint as true to determine if the Complaint 
states a “claim to relief that is plausible on its face.”  Braden v. Wal-Mart Stores, Inc., 
588 F.3d 585, 594
 (8th Cir. 2009) (quoting Ashcroft v. Iqbal, 
556 U.S. 662, 678
 (2009)).  The 

Court construes the Complaint in the light most favorable to the plaintiff, drawing all 
reasonable inferences in the plaintiff’s favor.  Ashley Cnty. v. Pfizer, Inc., 
552 F.3d 659, 665
 
(8th Cir. 2009).  Although the Court accepts the Complaint’s factual allegations as true, it 
is “not bound to accept as true a legal conclusion couched as a factual allegation,” Bell 

Atl. Corp. v. Twombly, 
550 U.S. 544, 555
 (2007), or mere “labels and conclusions or a 
formulaic recitation of the elements of a cause of action,” Iqbal, 
556 U.S. at 678
 (quotation 
omitted).  Instead, “[a] claim has facial plausibility when the plaintiff pleads factual 

content that allows the court to draw the reasonable inference that the defendant is 
liable for the misconduct alleged.”  
Id.
                                  
    At the motion to dismiss stage, the Court may consider the allegations in the 
Complaint as well as “those materials that are necessarily embraced by the pleadings.”  

Schriener v. Quicken Loans, Inc., 
774 F.3d 442, 444
 (8th Cir. 2014).  The Court may also 
consider matters of public record and exhibits attached to the pleadings, so long as those 
documents do not conflict with the Complaint.  Porous Media Corp. v. Pall Corp., 
186 F.3d 1077, 1079
 (8th Cir. 1999).                                               

    B.   Analysis                                                        
         1.   Substantive Due Process (Count II)                         
    Minnesota Statute § 35.155 imposes increased regulations on white-tail deer 
farms, thus increasing costs and hoops for deer farmers to jump through.  For instance, 

subdivision 10(c) prohibits the State from issuing new farming registrations, meaning 
there can be no new entrants into the industry.  The Plaintiffs argue that § 35.155’s 
various provisions, especially subdivision 10(c),7 deprives them of their fundamental right 
to pursue a common calling as white-tailed deer farmers and should be struck down under 

strict scrutiny.  Plaintiffs cite Conn v. Gabbert, in which the Supreme Court stated that 
“the liberty component of the Fourteenth Amendment’s Due Process Clause includes 
some generalized due process right to choose one’s field of private employment.” 
526 U.S. 286
, 291–92 (1999).  But see 
id.
 (clarifying that right “is nevertheless subject to 

reasonable government regulation”).  Defendants disagree and move to dismiss this claim 
because there is no fundamental right to farm deer.                       






    7 This argument applies to Mr. Udovich, the only Plaintiff without a valid registration who 
wishes to enter the white-tail deer farming profession in Minnesota.  (Compl. ¶¶ 170–71.)    
              a.   The  liberty  to  pursue  one’s  chosen  occupation  is  not  a 
                   fundamental right.                                    
    To  plead  a  cognizable  substantive  due  process  claim,  among  other  things,  a 
plaintiff must plead a violation of a fundamental right.  Karsjens v. Piper, 
845 F.3d 394, 408
 (8th Cir. 2017).  “For purposes of substantive due process analysis, fundamental rights 

are those ‘deeply rooted in this Nation’s history and tradition, and implicit in the concept 
of  ordered  liberty,  such  that  neither  liberty  nor  justice  would  exist  if  they  were 
sacrificed.’”  Flowers v. City of Minneapolis, 
478 F.3d 869, 873
 (8th Cir. 2007) (quoting 
Terrell v. Larson, 
396 F.3d 975
, 978 n.1 (8th Cir. 2005)).                

    Plaintiffs do not claim that they have a fundamental right to farm, nor could they.  
See United States v. Plume, 
447 F.3d 1067
, 1075 (8th Cir. 2006) (“The Supreme Court has 
not declared ‘farming’ to be a fundamental right, and we decline to do so today.”).  

Rather, Plaintiffs claim that they have a fundamental right to pursue their occupation as 
a white-tail deer farmer.                                                 
    The Supreme Court has recognized that there is a general liberty interest to pursue 
a particular calling or occupation.  Conn, 526 U.S. at 291–92; see also Robbins v. Becker, 

794 F.3d 988, 994
 (8th Cir. 2015); Habhab v. Hon, 
536 F.3d 963, 968
 (8th Cir. 2008).  
However, “[t]he fact that a right is acknowledged to be a liberty covered by the Due 
Process Clause does not automatically render that right ‘fundamental’ such that any 
statutory  regulation  of  that  right  must  be  subjected  to  the  highest  constitutional 

scrutiny.”  Rogers, 139 F. Supp. 3d at 157.  Accordingly, this Court and others have 
declined to extend due process protections to one’s ability to engage in their occupation 
or profession.  See Telescope Media Grp. v. Lindsey, 
271 F. Supp. 3d 1090
, 1127–28 (D. 

Minn. 2017), aff’d in part, rev’d in part on other grounds, and remanded sub nom. 
Telescope Media Grp. v. Lucero, 
936 F.3d 740
 (8th Cir. 2019); Doe v. Rogers, 
139 F.Supp.3d 120
,  156  &  n.23  (D.D.C.  2015)  (noting  that  “numerous  federal  circuit  courts  have 
concluded that the right to engage in a chosen profession is not a fundamental right” and 

collecting cases); Alemu v. Dep’t of For-Hire Vehicles, 
327 F. Supp. 3d 29
, 47–48 (D.D.C. 
2018) (rejecting plaintiff’s claim that the challenged state regulation deprived them of 
their fundamental right to work as self-employed taxicab drivers).        

    Indeed, neither the Supreme Court nor the Eighth Circuit have recognized that 
there  is  a  fundamental  right  to  work  or  operate  a  business  free  from  disfavored 
regulations.  See Williamson v. Lee Optical of Okla., Inc., 
348 U.S. 483, 488
 (1955) (“The 
day is gone when [courts] use[ ] the Due Process Clause of the Fourteenth Amendment 

to strike down state laws, regulatory of business and industrial conditions, because they 
may be unwise, improvident, or out of harmony with a particular school of thought.”); 
Singleton v. Cecil, 
176 F.3d 419, 429
 (8th Cir. 1999) (declining to consider “occupational 
liberty [as] sufficiently fundamental to qualify for substantive due process protection”).  

The Court will therefore not expand the reach of substantive due process to these facts.  
See Washington v. Glucksberg, 
521 U.S. 702, 720
 (1997) (noting the Supreme Court’s 
reluctance to expand substantive due process protections because it “place[s] the matter 
outside the arena of public debate and legislative action”); Albright v. Oliver, 
510 U.S. 266
, 
271–72 (1994) (same).                                                     

    To hold otherwise would lead to absurd results.  For instance, lead paint, asbestos, 
and ethylene oxide are banned because of their negative impact on public health.  (Reply 
Mot. Dismiss at 2–3, Mar. 28, 2024, Docket No. 30.)  But under Plaintiffs’ theory, an 
individual who operates or works for a company that manufactures such substances 

would  be  constitutionally  entitled  to  carry  on  their  dangerous  activities.    Likewise, 
physicians who wish to practice physician-assisted suicide could feasibly argue that they 
have been deprived of their ability to pursue their occupation despite Supreme Court 

precedent upholding state bans on such activities.  See Glucksberg, 
521 U.S. at 735
.  In 
sum,  under  Plaintiffs’  theory,  essentially  any  legislation  regulating  a  profession  or 
occupation would be subject to strict scrutiny.  Such a result “would be the equivalent of 
neutering the regulatory power of state government.”  See Kafka v. Hagener, 
176 F. Supp. 2d 1037, 1043
 (D. Mont. 2001) (rejecting the argument that Montana’s regulations 
banning fee killing of game farm animals implicates a fundamental right).   
    The  substantive  due  process  doctrine  is  “reserved  for  truly  egregious  and 
extraordinary cases,” which this is not.  Myers v. Scott County, 
868 F.2d 1017, 1018
 (8th 

Cir. 1989).  Moreover, the right to practice one’s chosen occupation bears no resemblance 
to other fundamental liberties, such as the “rights to marry; to have children; to direct 
the education and upbringing of one’s children; to marital privacy; to use contraception; 
[and] to bodily integrity.”  Glucksberg, 
521 U.S. at 720
 (citations omitted).  It cannot be 
that a woman has a constitutionally protected right to farm deer but not to access 

healthcare.  Dobbs v. Jackson Women’s Health Org., 
597 U.S. 215
, 239–40 (2022).   
    Because the right to pursue a chosen profession is not fundamental, rational basis 
applies.                                                                  
              b.   Minnesota Statute § 35.155 survives rational-basis review. 

    The Court must uphold the law if it is “rationally related to a legitimate state 
interest.” Birchansky v. Clabaugh, 
955 F.3d 751, 757
 (8th Cir. 2020).  The challenged 
statute is rational so long as there “is any reasonably conceivable state of facts that could 
provide a rational basis for the classification.”  F.C.C. v. Beach Commc’ns, Inc., 
508 U.S. 307, 313
 (1993).                                                          
    Plaintiffs argue that the statute is not rationally related to the prohibition of new 
white-tail deer registrations because the “evil” the State seeks to control is CWD, not 

white-tail deer  farmers.   However, the Minnesota  legislature  passed  the  statute  to 
prevent the spread of CWD, not to eliminate the white-tail deer farming profession.  The 
eventual  elimination  of  white-tail  deer  farming  in  Minnesota,  while  unfortunate,  is 
incidental.                                                               

    Rational basis review does not require the legislature to have chosen the most 
effective method of achieving its aim, and given the increase in CWD rates, the State could 
plausibly conclude that prohibiting new white-tail deer farms in Minnesota will effectively 
curtail the spread of CWD.  Birchansky, 
955 F.3d at 757
 (requiring only “plausible reasons 
for the legislature’s action” to survive rational-basis review) (cleaned up); see Spoklie v. 
Montana, 
411 F.3d 1051
, 1059 (9th Cir. 2005) (finding that the state’s justifications for 

passing a law that prohibits operating an alternative livestock ranch without a license and 
prohibits the issuance of new licenses “far exceed what is necessary to meet” rational-
basis review because “Voters who supported [the law] could rationally have concluded 
that the proposition would . . . prevent transmission of [CWD].”).        

    Thus,  because  Minnesota  Statute  §  35.155  rationally  relates  to  Minnesota’s 
legitimate state interest of addressing CWD, it survives rational-basis review.  Accordingly, 
the Court will grant Defendants’ Motion to Dismiss as to Count II.        

         2.   Equal Protection (Counts I & III)                          
    As discussed, Minnesota Statute § 35.155, subdivision 10(c) prohibits the issuance 
of new registrations to farm white-tail deer, and it limits white-tail deer registration 
holders to a one-time registration transfer to an immediate family member.  Plaintiffs 

argue that this provision makes two classifications that violate their rights: (1) it treats 
white-tailed  deer  farmers  without  immediate  family  differently  than  those  with 
immediate family by limiting the one-time registration transfer to immediate family 
members, and (2) it treats white-tail deer farmers “differently than all other livestock or 
poultry owners who may be subject to an infectious disease requiring the eradication of 
their animals or birds.”8  (Compl. ¶ 245.)                                

    “The Equal Protection Clause of the Fourteenth Amendment provides that no state 
shall ‘deny to any person within its jurisdiction the equal protection of the laws.’”  New 
Doe Child #1 v. United States, 
901 F.3d 1015, 1027
 (8th Cir. 2018) (quoting U.S. Const. 
amend. XIV, § 1).  “The Equal Protection Clause demands that similarly situated individuals 

be treated alike.”  Id.  “Unless a law burdens a fundamental right, targets a suspect class, 
or has a disparate impact on a protected class and was motivated by a discriminatory 
intent, we apply rational basis scrutiny to the challenged law.”  Id. (citing Pers. Adm’r of 

Mass.  v.  Feeney,  
442 U.S. 256, 272
  (1979)).    “[A]  classification  neither  involving 
fundamental rights nor proceeding along suspect lines is accorded a strong presumption 
of validity.”  Heller v. Doe ex rel. Doe, 
509 U.S. 312, 319
 (1993).  Plaintiffs bear the burden 
of proving “that the classification is so attenuated to its asserted purpose that the 

distinction it draws is wholly arbitrary and irrational.”  Gilmore v. Cnty. of Douglas, 
406 F.3d 935, 939
 (8th Cir. 2005) (quotation omitted).                        
    As the Court concluded, § 35.155 does not burden a fundamental right.  And 
neither classification is suspect nor quasi-suspect.  See City of Cleburne v. Cleburne Living 



    8 Plaintiffs also claim subdivisions (3) and (7) treat white-tail deer farmers differently than 
owners  of  other  livestock  and  poultry.    The  Court  assumes  Plaintiffs  intended  to  cite  to 
subdivisions  11(d)(3)  and  11(d)(7),  (see  Compl.  ¶¶  246–50  (citing  those  provisions,  not 
subdivisions (3) and (7)); however, the distinction does not matter because the Court will 
conclude all provisions pass rational-basis review.                       
Ctr., 
473 U.S. 432, 440
 (1985).  Accordingly, the statute is “presumed to be valid and will 
be sustained if the classification drawn by the statute is rationally related to a legitimate 

state interest.”  
Id.
                                                     
    Applying rational basis, the State presents “plausible reasons” for the legislature’s 
action.  Birchansky, 
955 F.3d at 757
.  First, under Minnesota Statute § 35.155 subdivision 
10(c), current white-tail deer registration holders can transfer their registration to an 

immediate family member one time.  The State passed this provision to allow one more 
generation of white-tail deer farming families an opportunity to pursue the profession.  
Although this provision may be underinclusive, the State is not required to issue a total 
ban.  See Gallagher v. City of Clayton, 
699 F.3d 1013, 1019
 (8th Cir. 2012) (upholding an 

underinclusive ordinance).  And it cannot be said that this “incremental” prohibition is “so 
attenuated to its asserted purpose that the distinction it draws is wholly arbitrary and 
irrational.”  Hawkeye Commodity Promotions, Inc. v. Vilsack, 
486 F.3d 430, 443
 (8th Cir. 

2007) (quoting Gilmore, 
406 F.3d at 939
).  Ultimately, even if the State could have adopted 
more effective measures, § 35.155’s immediate family member limitation furthers the 
State’s legitimate objective to prevent the spread of CWD by limiting the number of 
white-tail deer farms.                                                    

    Second, Plaintiffs argue § 35.155 violates their equal protection rights because it 
applies only to farmed Cervidae, not to other poultry and livestock owners.  To state an 
Equal Protection claim, plaintiffs must show that they were “treated differently than 
other persons who were ‘in all relevant respects similarly situated.’”  Flowers, 558 F.3d at 
798 (quoting Bills v. Dahm, 
32 F.3d 333, 335
 (8th Cir. 1994)).  Plaintiffs fail to demonstrate 

that they are similarly situated to poultry and livestock farmers.  As Plaintiffs acknowledge 
in their complaint, CWD is a transmissible disease that affects all Cervidae.  The statute 
applies to farmed Cervidae, which includes white-tail deer, mule deer, red deer, elk, 
moose, caribou, and sika.  Notably, poultry and other livestock, like cows and chickens, 

are not Cervidae and therefore are not impacted by CWD like white-tail deer.9  And 
Plaintiffs do not argue that white-tail deer farmers are treated differently than any other 
Cervidae farmers.  Therefore, Plaintiffs fail to demonstrate that they are similarly situated 

to  other livestock and poultry farmers because other livestock  and poultry are not 
susceptible to CWD like white-tail deer and other farmed Cervidae.  Accordingly, the Court 
will grant Defendants’ Motion to Dismiss as to Counts I and III.          






    9 Even if, as Plaintiffs argue, a CWD infected wild deer was found on a cattle pasture, the 
State could rationally conclude that a cattle rancher is not subject to the fencing restrictions, as 
the animals they raise are not susceptible to CWD.  Additionally, other livestock are less likely to 
interact with wild deer, which the fencing mandate aims to deter.  Regarding property records, 
if CWD is detected on an individual’s property, the individual “[can]not raise farmed Cervidae on 
the premises for at least ten years.”  See Minn. Stat. subd. 11(d)(5).  Thus, subdivision 11(d)(7)’s 
requirement that the CWD detection be recorded on property records for ten years ensures that 
future property owners are aware so that they do not farm Cervidae on the premises.  This 
certainly  is  rationally  related  to  the  State’s  objective  to  prevent  the  spread  of  CWD  by 
effectuating subdivision 11(d)(5).                                        
         3.   Takings Clause (Count IV)                                  
    Plaintiffs contend that the following provisions of § 35.155 constitute a taking: 

(1) subdivision  10,  which  allows  the  Commissioners  to  seize  and  destroy  illegally 
possessed  farmed Cervidae;  (2) subdivision  10(c), which  restrains the alienability of 
farmed Cervidae; (3) subdivision 11(d)(2), which authorizes the DNR to destroy herds 
where CWD has been detected; and (4) subdivisions 11(d)(3) and (d)(4), which require 

Cervidae farmers to erect fencing.  Plaintiffs do not seek money damages for their Takings 
claim, but rather request injunctive and declaratory relief.  Defendants respond that the 
Court  cannot  issue  an  injunction  because  the  State  is  immune  under  the  Eleventh 
Amendment and Ex Parte Young does not apply since Plaintiffs have failed to plead a 

continued violation of federal law.  The Court need not decide whether Defendants are 
immune,  however,  because  the  Supreme  Court  essentially  foreclosed  prospective 
injunctive and declaratory relief for Takings Clause claims in Knick v. Twp. of Scott, 
588 U.S. 180, 201
 (2019).                                                     
    The Fifth Amendment’s Takings Clause prohibits the government from taking 
“private property . . . for public use, without just compensation.” U.S. Const. amend. V.  
“The Fifth Amendment does not proscribe the taking of property; it proscribes taking 

without just compensation.”  Williamson Cty. Reg’l Planning Comm’n v. Hamilton Bank of 
Johnson City, 
473 U.S. 172, 194
 (1985), overruled on other grounds by Knick, 
588 U.S. at 206
.  Only when the government takes private property for public use without just 
compensation does a Takings Clause claim arise.  Knick, 
588 U.S. at 189
.  If a Plaintiff 
succeeds on a Takings Clause claim, the appropriate remedy is just compensation.  
Id. at 201
.  Injunctive relief is available only if the State does not have an “adequate provision 

for obtaining just compensation.”  
Id.
                                    
    The State’s inverse condemnation  statute  is generally adequate.  
Minn. Stat. § 117.045
;  see  e.g.,  Am.  Fam.  Ins.,  836  F.3d  at  924  (rejecting  the  argument  that 
Minnesota’s inverse condemnation procedures are futile).  Plaintiffs argue, however, that 

Minnesota’s remedy is inadequate as applied to their case because Minnesota’s inverse 
condemnation procedures would require “a repetitive series of lawsuits involving the 
same or different parties” with “facts [that] are similar, if not the same.”  (Mem. Supp. 

Mot. Prelim. Inj. at 25.)  Plaintiffs attempt to analogize the facts here to the facts in 
Pharmaceutical Research and Manufacturers of America v. Williams (“PhRMA”), 
64 F.4th 932
 (8th Cir. 2023).  This attempt is misguided.                          
    In PhRMA, three insulin manufacturers alleged that a Minnesota law requiring 

them to give eligible Minnesota residents a 30-day free supply of insulin was a taking.  
Id.
 
at 936–38.  The manufacturers argued that Minnesota’s inverse condemnation process 
was inadequate because it required them to seek a “continuous series of state court 
actions” compelling inverse condemnation proceedings for each of the thousands of 

insulin units sold.  
Id. at 939
.  The Eighth Circuit agreed and found Minnesota’s inverse 
condemnation  procedures  inadequate  because  it  required  insulin  manufacturers  to 
indefinitely engage in repetitive lawsuits.  
Id. at 945
.                  
    Here, Minnesota’s regulatory scheme will not result in the same injured party 
bringing an action against the same wrongdoer for one wrongful act.  See 
id. at 943
.  

Plaintiffs are dozens of white-tail deer farmers who may face different government action 
over time.  And each of the Plaintiffs’ potential claims may be different due to the value 
of the deer.  Moreover, it is not certain that the State will even engage in any takings 
without just compensation.  Indeed, Plaintiffs have not alleged that there has been a 

taking without just compensation to date.  And even if there has been, Plaintiffs fail to 
demonstrate that Minnesota’s inverse condemnation statute is inadequate.  As the Eighth 
Circuit acknowledged in PhRMA, in most cases the state law’s inverse condemnation 

procedures are adequate.  See 
id. at 942
.  Therefore, Plaintiffs are foreclosed from seeking 
equitable relief because they may bring an action seeking just compensation if a taking 
occurs.                                                                   
    To the extent Plaintiffs argue that the general statutory scheme constitutes a 

regulatory taking of the white-tail deer farming business, such contention is meritless.  
Under Penn Central, a regulation may amount to a taking in light of (1) its economic 
impact,  (2)  the  extent  to  which  it  has  interfered  with  distinct  investment-backed 
expectations, and (3) its character.  Penn Cent. Transp. Co. v. City of New York, 
438 U.S. 104, 124
 (1978).  First, the Court presumes that Plaintiffs will indeed incur a large expense 
by erecting the fence as mandated in subdivision (4); however, expense alone does not 
establish a regulatory taking.  
Id. at 131
 (rejecting the argument that diminution in 
property  value,  standing  alone,  constitutes  a  taking).10    Second,  Plaintiffs  fail  to 
demonstrate the regulation interferes with their investment-backed expectations.  The 

statute  does  not  prohibit  the  farmers  from  selling  deer,  slaughtering  the  deer,  or 
otherwise continuing to operate their businesses.  And § 35.155’s restriction on the 
alienation of a registration does not constitute a taking.11  Andrus v. Allard, 
444 U.S. 51
, 
65–66 (“where an owner possesses a full ‘bundle’ of property rights, the destruction of 

one ‘strand’ of the bundle is not a taking.”).  Moreover, Penn Central’s third prong—the 
character of the government action—considers the health, safety, and general welfare of 
the public.  
Id. at 125
.  Because the fencing mandate promotes those goals, there is no 

Takings Clause Claim.  Id.                                                
         4.   Procedural Due Process (Count IV)                          
    Plaintiffs  briefly  argue  that  the  DNR  implemented  an  additional  fencing 
requirement “without any rule-making process, including any emergency rule-making 

process, or public comment,” in violation of their due process rights.  (Compl. ¶ 319.)  



    10 Plaintiffs also claim that subdivision 11(d)(7)’s property recording mandate will diminish 
the value of their property when a sale occurs.  In addition to this claim not being ripe, diminution 
in property value, standing alone, is not a regulatory taking. Penn Cent., 
438 U.S. at 131
. 
    11 To the extent that Plaintiffs argue that § 35.155’s restriction on alienation of deer 
livestock to non-registered family members is a taking, that argument also fails.  The State may 
limit the selling of animals to individuals with the necessary registration or licenses. See Spoklie, 
411 F.3d at 1059 (finding a state law prohibiting the operating of an alternative livestock ranch 
without a license passes rational-basis review).  Additionally, as the State acknowledged in oral 
argument, Plaintiffs are permitted to sell their livestock to other registered white-tail deer 
farmers in the State and to individuals out of state, subject those state’s applicable laws.    
Plaintiffs reference the DNR’s website and claim that the website states several new 
fencing requirements.  (Mem. Supp. Mot. Prelim. Inj. at 10.)  The website, however, 

imposes no additional fencing requirements.  Instead, the DNR references Minnesota 
Statute § 35.155, subdivision 4 and provides a list of examples that satisfy § 35.155’s new 
fencing requirements.  Notably, underneath the examples of compliant fencing, the 
website states that “this document [does] not have the force and effect of law. This 

document is informational only and should not be interpreted as creating new criteria or 
requirements beyond what is already established in the relevant statutes and rules.”12   
    Therefore, because Plaintiffs failed to plead a due process violation, the Court will 

grant Defendants’ Motion to Dismiss as to Count IV.                       
II.  MOTION FOR PRELIMINARY INJUNCTION                                    
    Because  the  Court  will  grant  Defendants’  Motion  to  Dismiss  the  Amended 
Complaint in its entirety, the Court will deny as moot the Plaintiffs’ Motion for Preliminary 

Injunction.                                                               

ORDER

    Based on the foregoing, and all the files, records, and proceedings herein, IT IS 
HEREBY ORDERED:                                                           





    12 Deer Fencing, Minnesota Department of Natural Resources, https://www.dnr.state. 
mn.us/mammals/deer/management/deer-fencing.html (last visited Aug. 12, 2024). 
     1.   Defendants’  Motion  to  Dismiss  Amended  Complaint  [Docket  No.  13]  is 
        GRANTED; 
     2.  Plaintiffs’ Amended Complaint [Docket No. 12] is DISMISSED WITH PREJUDICE; 
        and 
     3.  Plaintiffs’ Motion for Preliminary Injunction [Docket No. 18] is DENIED as moot. 
     LET JUDGMENT BE ENTERED ACCORDINGLY. 

DATED:  August 14, 2024                           dob, □□□ (deen 
at Minneapolis, Minnesota.                         JOHN R. TUNHEIM 
                                            United States District Judge 

                                    -21- 

Trial Court Opinion

                   UNITED STATES DISTRICT COURT                          
                      DISTRICT OF MINNESOTA                              

MINNESOTA DEER FARMERS                Civil No. 23-3907 (JRT/LIB)        
ASSOCIATION, et al.,                                                     

                       Plaintiffs,  MEMORANDUM OPINION AND               
                                   ORDER GRANTING DEFENDANTS’            
v.                                    MOTION TO DISMISS AND              
                                    DENYING PLAINTIFFS’ MOTION           
SARAH STROMMEN, in her official     FOR PRELIMINARY INJUNCTION           
capacity as Commissioner of the                                          
Minnesota Department of Natural                                          
Resources, et al.,                                                       

                      Defendants.                                        

    Erick  G.  Kaardal  and  Gregory  M.  Erickson,  MOHRMAN,  KAARDAL  & 
    ERICKSON, P.A., 150 South Fifth Street, Suite 3100, Minneapolis, MN 55402, 
    for Plaintiffs.                                                      

    Philip Pulitzer, MINNESOTA ATTORNEY GENERAL’S OFFICE, 445 Minnesota  
    Street, Suite 900, Saint Paul, MN 55101, for Defendants.             

    In 2023, the Minnesota legislature passed legislation intended to combat the 
spread of Chronic Wasting Disease (“CWD”), an illness found in white-tailed deer that is 
incurable, fatal, and potentially transmissible to humans.  The legislation, among other 
changes, increases regulatory oversight of white-tail deer farms and vests that oversight 
with the Minnesota Department of Natural Resources (“DNR”), requires the farmers to 
erect fences to prevent exposure to wild deer, restricts the transfer of white-tail deer 
farm registrations, and prohibits the issuance of new white-tail deer farm registrations.   
    The Minnesota Deer Farmers Association, a Minnesota nonprofit corporation that 
advocates on behalf of deer farmers, and the deer farmers themselves (collectively 

“Plaintiffs”),  brought  this  action  against  DNR  Commissioner  Strommen  and  several 
Minnesota Board of Animal Health (“BAH”) board members in their official capacities 
(collectively “Defendants”), claiming that the legislation violates their due process and 
equal protection rights under the Fourteenth Amendment and their Fifth Amendment 

right  to  be  free  from  unconstitutional  property  seizures.    Plaintiffs  also  request  a 
preliminary injunction enjoining enforcement of Minnesota Statute § 35.155, subdivision 
10(c), and the additional exclusionary fencing requirements.              

    The State enacted § 35.155 to address CWD, a growing health concern that experts 
say could develop into a public health crisis if left unmanaged, which is certainly a 
legitimate state interest that passes rational-basis review.  Plaintiffs thus fail to plead a 
cognizable claim under the Due Process Clause or the Equal Protection Clause.  Plaintiffs 

Fifth Amendment Takings Clause claim also fails as a matter of law.  Accordingly, the Court 
will grant Defendants’ Motion to Dismiss and will deny Plaintiffs’ Motion for Preliminary 
Injunction as moot.                                                       
                          BACKGROUND                                     

    White-tail deer are part of the farmed Cervidae family, which also include mule 
deer, red deer, elk, moose, caribou, and sika.  (Am. Compl. (“Compl.”) ¶ 217, Feb. 12, 
2024,  Docket  No.  12.)    Cervidae  are  susceptible  to  CWD,  an  incurable,  infectious, 
neurological disease of the Cervidae family.1  If a Cervidae, like a white-tailed deer, is 
infected with CWD, the animal’s brain cells deteriorate to a spongy consistency, causing 

the animal to eventually die.  (Compl. ¶¶ 215, 220–21; Mem. Supp. Mot. Prelim. Inj. at 5, 
Feb. 23, 2024, Docket No. 20.)                                            
    Although CWD has previously been considered only a threat to Cervidae, studies 
have recently opined that it may be transmissible to humans.2  Due to this concern and 

the disease’s spread throughout the United States, including into Minnesota, the State 
passed Minnesota Laws 2023, Chapter 60, Article 7, Sections 1–14 (codified at 
Minn. Stat. § 35.155
) to contain and stop the transmission of CWD.3  (Compl. ¶¶ 218–19, 222.) 

    Minnesota has historically regulated the white-tail deer farming industry heavily.  
Section  35.155  continues  to  tighten  regulations,  largely  due  to  the  Minnesota 
Department of Natural Resources 2022 Legislative Report (“Report”), which identified 
farmed Cervidae as a major culprit in introducing CWD to Minnesota.4  The Report also 

noted the hefty cost of CWD surveillance and regulatory oversight of deer farms.5   As a 


    1 Minnesota Dep’t of Nat. Res., Report: Concurrent Authority Regulating Farmed White-
tailed Deer 5 (Feb. 1, 2022), https://files.dnr.state.mn.us/aboutdnr/reports/legislative/2022/con 
current-authority-legislative-report-farmed-deer.pdf.                     
    2 Chronic Wasting Disease, CDC (Apr. 17, 2024), https://www.cdc.gov/chronic-wasting.  
The Court will take judicial notice of CWD’s exposure risks, as detailed on the CDC’s website.  Fed. 
R. Evid. 201(c)(1); see Missourians for Fiscal Accountability v. Klahr, 
830 F.3d 789, 793
 (8th Cir. 
2016) (recognizing authority to take judicial notice of government websites).   
    3 Minnesota Dep’t of Nat. Res., supra note 1 at 5.                   
    4 Id. at 2–3.                                                        
    5 Id. at 6 (noting that the State spent $55,176 on CWD testing in farmed Cervidae and $2.9 
million on CWD activities for wild deer).                                 
result of their findings, the DNR and BAH recommended greater regulation of deer farms 
and heightened fencing requirements.6  The Minnesota Legislature heeded the agencies’ 

recommendations, introducing new and amending existing farmed Cervidae regulations.  
See 
Minn. Stat. § 35.155
.  The subdivisions at issue include:             
    Subdivision 4 details fencing requirements for Farmed Cervidae.      
    Subdivision 10 requires a registration to possess Cervidae, prohibits the State from 

    issuing  new  registrations  to  possess  white-tailed  deer,  and  limits  current 
    registration holders to a one-time transfer to an immediate family member. 
    Subdivision 11(d)(3), upon CWD detection, requires maintaining a fence on the 

    premises for ten years.                                              
    Subdivision 11(d)(5) prohibits raising farmed Cervidae on the premises for ten 
    years upon CWD detection.                                            
    Subdivisions 11(d)(6), upon CWD detection, requires disclosing to a property 

    buyer the date of herd depopulation and the requirements incumbent upon the 
    premises.                                                            
    Subdivision  11(d)(7),  upon  CWD  detection,  mandates  recording  with  the 
    applicable county recorder “the date of detection, the date of depopulation, the 

    landowner  requirements  under  this  paragraph,  and  any  other  information 



    6 
Id.
 at 7–8.                                                        
    required by the board . . . The notice expires and has no effect ten years after the 
    date of detection stated in the notice.”                             

Minn. Stat. § 35.155
 subds. 4, 10–11.                                     

    While Defendant Commissioner Strommen leads the DNR and is charged with 
overseeing, enforcing, and implementing Minnesota Statute § 35.155, the Commissioner 
may contract with the BAH to administer such provisions.  See 
Minn. Stat. § 35.155
 subd. 
15(a).                                                                    
    Plaintiffs allege that (1) § 35.155, subd. 10(c) violates their substantive due process 
rights  under  the  Fourteenth  Amendment  because  it  deprives  Plaintiffs  of  their 

fundamental right to pursue a common calling as white-tailed deer farmers; (2) § 35.155, 
subd. 10(c) violates their right to equal protection under the Fourteenth Amendment by 
advantaging  those  with  immediate  family  over  those  without  and  by  treating  deer 
farmers more stringently than other livestock farmers; (3) § 35.155, subds. 4, 10, and 11 

violate the Takings Clause of the Fifth Amendment; and (4) the DNR’s additional fencing 
requirement violates due process protection because it was implemented without any 
rule-making process.  (Compl. ¶¶ 229–329.)  Additionally, Plaintiffs seek injunctive relief 
against the enforcement of Minnesota Statute § 35.155 subdivision 10(c).  (Id. pp. 63–64.) 
                           DISCUSSION                                    
I.   MOTION TO DISMISS                                                    
    A.   Standard of review                                              

    In reviewing a motion to dismiss under Federal Rule of Civil Procedure 12(b)(6), the 
Court considers all facts alleged in the Complaint as true to determine if the Complaint 
states a “claim to relief that is plausible on its face.”  Braden v. Wal-Mart Stores, Inc., 
588 F.3d 585, 594
 (8th Cir. 2009) (quoting Ashcroft v. Iqbal, 
556 U.S. 662, 678
 (2009)).  The 

Court construes the Complaint in the light most favorable to the plaintiff, drawing all 
reasonable inferences in the plaintiff’s favor.  Ashley Cnty. v. Pfizer, Inc., 
552 F.3d 659, 665
 
(8th Cir. 2009).  Although the Court accepts the Complaint’s factual allegations as true, it 
is “not bound to accept as true a legal conclusion couched as a factual allegation,” Bell 

Atl. Corp. v. Twombly, 
550 U.S. 544, 555
 (2007), or mere “labels and conclusions or a 
formulaic recitation of the elements of a cause of action,” Iqbal, 
556 U.S. at 678
 (quotation 
omitted).  Instead, “[a] claim has facial plausibility when the plaintiff pleads factual 

content that allows the court to draw the reasonable inference that the defendant is 
liable for the misconduct alleged.”  
Id.
                                  
    At the motion to dismiss stage, the Court may consider the allegations in the 
Complaint as well as “those materials that are necessarily embraced by the pleadings.”  

Schriener v. Quicken Loans, Inc., 
774 F.3d 442, 444
 (8th Cir. 2014).  The Court may also 
consider matters of public record and exhibits attached to the pleadings, so long as those 
documents do not conflict with the Complaint.  Porous Media Corp. v. Pall Corp., 
186 F.3d 1077, 1079
 (8th Cir. 1999).                                               

    B.   Analysis                                                        
         1.   Substantive Due Process (Count II)                         
    Minnesota Statute § 35.155 imposes increased regulations on white-tail deer 
farms, thus increasing costs and hoops for deer farmers to jump through.  For instance, 

subdivision 10(c) prohibits the State from issuing new farming registrations, meaning 
there can be no new entrants into the industry.  The Plaintiffs argue that § 35.155’s 
various provisions, especially subdivision 10(c),7 deprives them of their fundamental right 
to pursue a common calling as white-tailed deer farmers and should be struck down under 

strict scrutiny.  Plaintiffs cite Conn v. Gabbert, in which the Supreme Court stated that 
“the liberty component of the Fourteenth Amendment’s Due Process Clause includes 
some generalized due process right to choose one’s field of private employment.” 
526 U.S. 286
, 291–92 (1999).  But see 
id.
 (clarifying that right “is nevertheless subject to 

reasonable government regulation”).  Defendants disagree and move to dismiss this claim 
because there is no fundamental right to farm deer.                       






    7 This argument applies to Mr. Udovich, the only Plaintiff without a valid registration who 
wishes to enter the white-tail deer farming profession in Minnesota.  (Compl. ¶¶ 170–71.)    
              a.   The  liberty  to  pursue  one’s  chosen  occupation  is  not  a 
                   fundamental right.                                    
    To  plead  a  cognizable  substantive  due  process  claim,  among  other  things,  a 
plaintiff must plead a violation of a fundamental right.  Karsjens v. Piper, 
845 F.3d 394, 408
 (8th Cir. 2017).  “For purposes of substantive due process analysis, fundamental rights 

are those ‘deeply rooted in this Nation’s history and tradition, and implicit in the concept 
of  ordered  liberty,  such  that  neither  liberty  nor  justice  would  exist  if  they  were 
sacrificed.’”  Flowers v. City of Minneapolis, 
478 F.3d 869, 873
 (8th Cir. 2007) (quoting 
Terrell v. Larson, 
396 F.3d 975
, 978 n.1 (8th Cir. 2005)).                

    Plaintiffs do not claim that they have a fundamental right to farm, nor could they.  
See United States v. Plume, 
447 F.3d 1067
, 1075 (8th Cir. 2006) (“The Supreme Court has 
not declared ‘farming’ to be a fundamental right, and we decline to do so today.”).  

Rather, Plaintiffs claim that they have a fundamental right to pursue their occupation as 
a white-tail deer farmer.                                                 
    The Supreme Court has recognized that there is a general liberty interest to pursue 
a particular calling or occupation.  Conn, 526 U.S. at 291–92; see also Robbins v. Becker, 

794 F.3d 988, 994
 (8th Cir. 2015); Habhab v. Hon, 
536 F.3d 963, 968
 (8th Cir. 2008).  
However, “[t]he fact that a right is acknowledged to be a liberty covered by the Due 
Process Clause does not automatically render that right ‘fundamental’ such that any 
statutory  regulation  of  that  right  must  be  subjected  to  the  highest  constitutional 

scrutiny.”  Rogers, 139 F. Supp. 3d at 157.  Accordingly, this Court and others have 
declined to extend due process protections to one’s ability to engage in their occupation 
or profession.  See Telescope Media Grp. v. Lindsey, 
271 F. Supp. 3d 1090
, 1127–28 (D. 

Minn. 2017), aff’d in part, rev’d in part on other grounds, and remanded sub nom. 
Telescope Media Grp. v. Lucero, 
936 F.3d 740
 (8th Cir. 2019); Doe v. Rogers, 
139 F.Supp.3d 120
,  156  &  n.23  (D.D.C.  2015)  (noting  that  “numerous  federal  circuit  courts  have 
concluded that the right to engage in a chosen profession is not a fundamental right” and 

collecting cases); Alemu v. Dep’t of For-Hire Vehicles, 
327 F. Supp. 3d 29
, 47–48 (D.D.C. 
2018) (rejecting plaintiff’s claim that the challenged state regulation deprived them of 
their fundamental right to work as self-employed taxicab drivers).        

    Indeed, neither the Supreme Court nor the Eighth Circuit have recognized that 
there  is  a  fundamental  right  to  work  or  operate  a  business  free  from  disfavored 
regulations.  See Williamson v. Lee Optical of Okla., Inc., 
348 U.S. 483, 488
 (1955) (“The 
day is gone when [courts] use[ ] the Due Process Clause of the Fourteenth Amendment 

to strike down state laws, regulatory of business and industrial conditions, because they 
may be unwise, improvident, or out of harmony with a particular school of thought.”); 
Singleton v. Cecil, 
176 F.3d 419, 429
 (8th Cir. 1999) (declining to consider “occupational 
liberty [as] sufficiently fundamental to qualify for substantive due process protection”).  

The Court will therefore not expand the reach of substantive due process to these facts.  
See Washington v. Glucksberg, 
521 U.S. 702, 720
 (1997) (noting the Supreme Court’s 
reluctance to expand substantive due process protections because it “place[s] the matter 
outside the arena of public debate and legislative action”); Albright v. Oliver, 
510 U.S. 266
, 
271–72 (1994) (same).                                                     

    To hold otherwise would lead to absurd results.  For instance, lead paint, asbestos, 
and ethylene oxide are banned because of their negative impact on public health.  (Reply 
Mot. Dismiss at 2–3, Mar. 28, 2024, Docket No. 30.)  But under Plaintiffs’ theory, an 
individual who operates or works for a company that manufactures such substances 

would  be  constitutionally  entitled  to  carry  on  their  dangerous  activities.    Likewise, 
physicians who wish to practice physician-assisted suicide could feasibly argue that they 
have been deprived of their ability to pursue their occupation despite Supreme Court 

precedent upholding state bans on such activities.  See Glucksberg, 
521 U.S. at 735
.  In 
sum,  under  Plaintiffs’  theory,  essentially  any  legislation  regulating  a  profession  or 
occupation would be subject to strict scrutiny.  Such a result “would be the equivalent of 
neutering the regulatory power of state government.”  See Kafka v. Hagener, 
176 F. Supp. 2d 1037, 1043
 (D. Mont. 2001) (rejecting the argument that Montana’s regulations 
banning fee killing of game farm animals implicates a fundamental right).   
    The  substantive  due  process  doctrine  is  “reserved  for  truly  egregious  and 
extraordinary cases,” which this is not.  Myers v. Scott County, 
868 F.2d 1017, 1018
 (8th 

Cir. 1989).  Moreover, the right to practice one’s chosen occupation bears no resemblance 
to other fundamental liberties, such as the “rights to marry; to have children; to direct 
the education and upbringing of one’s children; to marital privacy; to use contraception; 
[and] to bodily integrity.”  Glucksberg, 
521 U.S. at 720
 (citations omitted).  It cannot be 
that a woman has a constitutionally protected right to farm deer but not to access 

healthcare.  Dobbs v. Jackson Women’s Health Org., 
597 U.S. 215
, 239–40 (2022).   
    Because the right to pursue a chosen profession is not fundamental, rational basis 
applies.                                                                  
              b.   Minnesota Statute § 35.155 survives rational-basis review. 

    The Court must uphold the law if it is “rationally related to a legitimate state 
interest.” Birchansky v. Clabaugh, 
955 F.3d 751, 757
 (8th Cir. 2020).  The challenged 
statute is rational so long as there “is any reasonably conceivable state of facts that could 
provide a rational basis for the classification.”  F.C.C. v. Beach Commc’ns, Inc., 
508 U.S. 307, 313
 (1993).                                                          
    Plaintiffs argue that the statute is not rationally related to the prohibition of new 
white-tail deer registrations because the “evil” the State seeks to control is CWD, not 

white-tail deer  farmers.   However, the Minnesota  legislature  passed  the  statute  to 
prevent the spread of CWD, not to eliminate the white-tail deer farming profession.  The 
eventual  elimination  of  white-tail  deer  farming  in  Minnesota,  while  unfortunate,  is 
incidental.                                                               

    Rational basis review does not require the legislature to have chosen the most 
effective method of achieving its aim, and given the increase in CWD rates, the State could 
plausibly conclude that prohibiting new white-tail deer farms in Minnesota will effectively 
curtail the spread of CWD.  Birchansky, 
955 F.3d at 757
 (requiring only “plausible reasons 
for the legislature’s action” to survive rational-basis review) (cleaned up); see Spoklie v. 
Montana, 
411 F.3d 1051
, 1059 (9th Cir. 2005) (finding that the state’s justifications for 

passing a law that prohibits operating an alternative livestock ranch without a license and 
prohibits the issuance of new licenses “far exceed what is necessary to meet” rational-
basis review because “Voters who supported [the law] could rationally have concluded 
that the proposition would . . . prevent transmission of [CWD].”).        

    Thus,  because  Minnesota  Statute  §  35.155  rationally  relates  to  Minnesota’s 
legitimate state interest of addressing CWD, it survives rational-basis review.  Accordingly, 
the Court will grant Defendants’ Motion to Dismiss as to Count II.        

         2.   Equal Protection (Counts I & III)                          
    As discussed, Minnesota Statute § 35.155, subdivision 10(c) prohibits the issuance 
of new registrations to farm white-tail deer, and it limits white-tail deer registration 
holders to a one-time registration transfer to an immediate family member.  Plaintiffs 

argue that this provision makes two classifications that violate their rights: (1) it treats 
white-tailed  deer  farmers  without  immediate  family  differently  than  those  with 
immediate family by limiting the one-time registration transfer to immediate family 
members, and (2) it treats white-tail deer farmers “differently than all other livestock or 
poultry owners who may be subject to an infectious disease requiring the eradication of 
their animals or birds.”8  (Compl. ¶ 245.)                                

    “The Equal Protection Clause of the Fourteenth Amendment provides that no state 
shall ‘deny to any person within its jurisdiction the equal protection of the laws.’”  New 
Doe Child #1 v. United States, 
901 F.3d 1015, 1027
 (8th Cir. 2018) (quoting U.S. Const. 
amend. XIV, § 1).  “The Equal Protection Clause demands that similarly situated individuals 

be treated alike.”  Id.  “Unless a law burdens a fundamental right, targets a suspect class, 
or has a disparate impact on a protected class and was motivated by a discriminatory 
intent, we apply rational basis scrutiny to the challenged law.”  Id. (citing Pers. Adm’r of 

Mass.  v.  Feeney,  
442 U.S. 256, 272
  (1979)).    “[A]  classification  neither  involving 
fundamental rights nor proceeding along suspect lines is accorded a strong presumption 
of validity.”  Heller v. Doe ex rel. Doe, 
509 U.S. 312, 319
 (1993).  Plaintiffs bear the burden 
of proving “that the classification is so attenuated to its asserted purpose that the 

distinction it draws is wholly arbitrary and irrational.”  Gilmore v. Cnty. of Douglas, 
406 F.3d 935, 939
 (8th Cir. 2005) (quotation omitted).                        
    As the Court concluded, § 35.155 does not burden a fundamental right.  And 
neither classification is suspect nor quasi-suspect.  See City of Cleburne v. Cleburne Living 



    8 Plaintiffs also claim subdivisions (3) and (7) treat white-tail deer farmers differently than 
owners  of  other  livestock  and  poultry.    The  Court  assumes  Plaintiffs  intended  to  cite  to 
subdivisions  11(d)(3)  and  11(d)(7),  (see  Compl.  ¶¶  246–50  (citing  those  provisions,  not 
subdivisions (3) and (7)); however, the distinction does not matter because the Court will 
conclude all provisions pass rational-basis review.                       
Ctr., 
473 U.S. 432, 440
 (1985).  Accordingly, the statute is “presumed to be valid and will 
be sustained if the classification drawn by the statute is rationally related to a legitimate 

state interest.”  
Id.
                                                     
    Applying rational basis, the State presents “plausible reasons” for the legislature’s 
action.  Birchansky, 
955 F.3d at 757
.  First, under Minnesota Statute § 35.155 subdivision 
10(c), current white-tail deer registration holders can transfer their registration to an 

immediate family member one time.  The State passed this provision to allow one more 
generation of white-tail deer farming families an opportunity to pursue the profession.  
Although this provision may be underinclusive, the State is not required to issue a total 
ban.  See Gallagher v. City of Clayton, 
699 F.3d 1013, 1019
 (8th Cir. 2012) (upholding an 

underinclusive ordinance).  And it cannot be said that this “incremental” prohibition is “so 
attenuated to its asserted purpose that the distinction it draws is wholly arbitrary and 
irrational.”  Hawkeye Commodity Promotions, Inc. v. Vilsack, 
486 F.3d 430, 443
 (8th Cir. 

2007) (quoting Gilmore, 
406 F.3d at 939
).  Ultimately, even if the State could have adopted 
more effective measures, § 35.155’s immediate family member limitation furthers the 
State’s legitimate objective to prevent the spread of CWD by limiting the number of 
white-tail deer farms.                                                    

    Second, Plaintiffs argue § 35.155 violates their equal protection rights because it 
applies only to farmed Cervidae, not to other poultry and livestock owners.  To state an 
Equal Protection claim, plaintiffs must show that they were “treated differently than 
other persons who were ‘in all relevant respects similarly situated.’”  Flowers, 558 F.3d at 
798 (quoting Bills v. Dahm, 
32 F.3d 333, 335
 (8th Cir. 1994)).  Plaintiffs fail to demonstrate 

that they are similarly situated to poultry and livestock farmers.  As Plaintiffs acknowledge 
in their complaint, CWD is a transmissible disease that affects all Cervidae.  The statute 
applies to farmed Cervidae, which includes white-tail deer, mule deer, red deer, elk, 
moose, caribou, and sika.  Notably, poultry and other livestock, like cows and chickens, 

are not Cervidae and therefore are not impacted by CWD like white-tail deer.9  And 
Plaintiffs do not argue that white-tail deer farmers are treated differently than any other 
Cervidae farmers.  Therefore, Plaintiffs fail to demonstrate that they are similarly situated 

to  other livestock and poultry farmers because other livestock  and poultry are not 
susceptible to CWD like white-tail deer and other farmed Cervidae.  Accordingly, the Court 
will grant Defendants’ Motion to Dismiss as to Counts I and III.          






    9 Even if, as Plaintiffs argue, a CWD infected wild deer was found on a cattle pasture, the 
State could rationally conclude that a cattle rancher is not subject to the fencing restrictions, as 
the animals they raise are not susceptible to CWD.  Additionally, other livestock are less likely to 
interact with wild deer, which the fencing mandate aims to deter.  Regarding property records, 
if CWD is detected on an individual’s property, the individual “[can]not raise farmed Cervidae on 
the premises for at least ten years.”  See Minn. Stat. subd. 11(d)(5).  Thus, subdivision 11(d)(7)’s 
requirement that the CWD detection be recorded on property records for ten years ensures that 
future property owners are aware so that they do not farm Cervidae on the premises.  This 
certainly  is  rationally  related  to  the  State’s  objective  to  prevent  the  spread  of  CWD  by 
effectuating subdivision 11(d)(5).                                        
         3.   Takings Clause (Count IV)                                  
    Plaintiffs contend that the following provisions of § 35.155 constitute a taking: 

(1) subdivision  10,  which  allows  the  Commissioners  to  seize  and  destroy  illegally 
possessed  farmed Cervidae;  (2) subdivision  10(c), which  restrains the alienability of 
farmed Cervidae; (3) subdivision 11(d)(2), which authorizes the DNR to destroy herds 
where CWD has been detected; and (4) subdivisions 11(d)(3) and (d)(4), which require 

Cervidae farmers to erect fencing.  Plaintiffs do not seek money damages for their Takings 
claim, but rather request injunctive and declaratory relief.  Defendants respond that the 
Court  cannot  issue  an  injunction  because  the  State  is  immune  under  the  Eleventh 
Amendment and Ex Parte Young does not apply since Plaintiffs have failed to plead a 

continued violation of federal law.  The Court need not decide whether Defendants are 
immune,  however,  because  the  Supreme  Court  essentially  foreclosed  prospective 
injunctive and declaratory relief for Takings Clause claims in Knick v. Twp. of Scott, 
588 U.S. 180, 201
 (2019).                                                     
    The Fifth Amendment’s Takings Clause prohibits the government from taking 
“private property . . . for public use, without just compensation.” U.S. Const. amend. V.  
“The Fifth Amendment does not proscribe the taking of property; it proscribes taking 

without just compensation.”  Williamson Cty. Reg’l Planning Comm’n v. Hamilton Bank of 
Johnson City, 
473 U.S. 172, 194
 (1985), overruled on other grounds by Knick, 
588 U.S. at 206
.  Only when the government takes private property for public use without just 
compensation does a Takings Clause claim arise.  Knick, 
588 U.S. at 189
.  If a Plaintiff 
succeeds on a Takings Clause claim, the appropriate remedy is just compensation.  
Id. at 201
.  Injunctive relief is available only if the State does not have an “adequate provision 

for obtaining just compensation.”  
Id.
                                    
    The State’s inverse condemnation  statute  is generally adequate.  
Minn. Stat. § 117.045
;  see  e.g.,  Am.  Fam.  Ins.,  836  F.3d  at  924  (rejecting  the  argument  that 
Minnesota’s inverse condemnation procedures are futile).  Plaintiffs argue, however, that 

Minnesota’s remedy is inadequate as applied to their case because Minnesota’s inverse 
condemnation procedures would require “a repetitive series of lawsuits involving the 
same or different parties” with “facts [that] are similar, if not the same.”  (Mem. Supp. 

Mot. Prelim. Inj. at 25.)  Plaintiffs attempt to analogize the facts here to the facts in 
Pharmaceutical Research and Manufacturers of America v. Williams (“PhRMA”), 
64 F.4th 932
 (8th Cir. 2023).  This attempt is misguided.                          
    In PhRMA, three insulin manufacturers alleged that a Minnesota law requiring 

them to give eligible Minnesota residents a 30-day free supply of insulin was a taking.  
Id.
 
at 936–38.  The manufacturers argued that Minnesota’s inverse condemnation process 
was inadequate because it required them to seek a “continuous series of state court 
actions” compelling inverse condemnation proceedings for each of the thousands of 

insulin units sold.  
Id. at 939
.  The Eighth Circuit agreed and found Minnesota’s inverse 
condemnation  procedures  inadequate  because  it  required  insulin  manufacturers  to 
indefinitely engage in repetitive lawsuits.  
Id. at 945
.                  
    Here, Minnesota’s regulatory scheme will not result in the same injured party 
bringing an action against the same wrongdoer for one wrongful act.  See 
id. at 943
.  

Plaintiffs are dozens of white-tail deer farmers who may face different government action 
over time.  And each of the Plaintiffs’ potential claims may be different due to the value 
of the deer.  Moreover, it is not certain that the State will even engage in any takings 
without just compensation.  Indeed, Plaintiffs have not alleged that there has been a 

taking without just compensation to date.  And even if there has been, Plaintiffs fail to 
demonstrate that Minnesota’s inverse condemnation statute is inadequate.  As the Eighth 
Circuit acknowledged in PhRMA, in most cases the state law’s inverse condemnation 

procedures are adequate.  See 
id. at 942
.  Therefore, Plaintiffs are foreclosed from seeking 
equitable relief because they may bring an action seeking just compensation if a taking 
occurs.                                                                   
    To the extent Plaintiffs argue that the general statutory scheme constitutes a 

regulatory taking of the white-tail deer farming business, such contention is meritless.  
Under Penn Central, a regulation may amount to a taking in light of (1) its economic 
impact,  (2)  the  extent  to  which  it  has  interfered  with  distinct  investment-backed 
expectations, and (3) its character.  Penn Cent. Transp. Co. v. City of New York, 
438 U.S. 104, 124
 (1978).  First, the Court presumes that Plaintiffs will indeed incur a large expense 
by erecting the fence as mandated in subdivision (4); however, expense alone does not 
establish a regulatory taking.  
Id. at 131
 (rejecting the argument that diminution in 
property  value,  standing  alone,  constitutes  a  taking).10    Second,  Plaintiffs  fail  to 
demonstrate the regulation interferes with their investment-backed expectations.  The 

statute  does  not  prohibit  the  farmers  from  selling  deer,  slaughtering  the  deer,  or 
otherwise continuing to operate their businesses.  And § 35.155’s restriction on the 
alienation of a registration does not constitute a taking.11  Andrus v. Allard, 
444 U.S. 51
, 
65–66 (“where an owner possesses a full ‘bundle’ of property rights, the destruction of 

one ‘strand’ of the bundle is not a taking.”).  Moreover, Penn Central’s third prong—the 
character of the government action—considers the health, safety, and general welfare of 
the public.  
Id. at 125
.  Because the fencing mandate promotes those goals, there is no 

Takings Clause Claim.  Id.                                                
         4.   Procedural Due Process (Count IV)                          
    Plaintiffs  briefly  argue  that  the  DNR  implemented  an  additional  fencing 
requirement “without any rule-making process, including any emergency rule-making 

process, or public comment,” in violation of their due process rights.  (Compl. ¶ 319.)  



    10 Plaintiffs also claim that subdivision 11(d)(7)’s property recording mandate will diminish 
the value of their property when a sale occurs.  In addition to this claim not being ripe, diminution 
in property value, standing alone, is not a regulatory taking. Penn Cent., 
438 U.S. at 131
. 
    11 To the extent that Plaintiffs argue that § 35.155’s restriction on alienation of deer 
livestock to non-registered family members is a taking, that argument also fails.  The State may 
limit the selling of animals to individuals with the necessary registration or licenses. See Spoklie, 
411 F.3d at 1059 (finding a state law prohibiting the operating of an alternative livestock ranch 
without a license passes rational-basis review).  Additionally, as the State acknowledged in oral 
argument, Plaintiffs are permitted to sell their livestock to other registered white-tail deer 
farmers in the State and to individuals out of state, subject those state’s applicable laws.    
Plaintiffs reference the DNR’s website and claim that the website states several new 
fencing requirements.  (Mem. Supp. Mot. Prelim. Inj. at 10.)  The website, however, 

imposes no additional fencing requirements.  Instead, the DNR references Minnesota 
Statute § 35.155, subdivision 4 and provides a list of examples that satisfy § 35.155’s new 
fencing requirements.  Notably, underneath the examples of compliant fencing, the 
website states that “this document [does] not have the force and effect of law. This 

document is informational only and should not be interpreted as creating new criteria or 
requirements beyond what is already established in the relevant statutes and rules.”12   
    Therefore, because Plaintiffs failed to plead a due process violation, the Court will 

grant Defendants’ Motion to Dismiss as to Count IV.                       
II.  MOTION FOR PRELIMINARY INJUNCTION                                    
    Because  the  Court  will  grant  Defendants’  Motion  to  Dismiss  the  Amended 
Complaint in its entirety, the Court will deny as moot the Plaintiffs’ Motion for Preliminary 

Injunction.                                                               

ORDER

    Based on the foregoing, and all the files, records, and proceedings herein, IT IS 
HEREBY ORDERED:                                                           





    12 Deer Fencing, Minnesota Department of Natural Resources, https://www.dnr.state. 
mn.us/mammals/deer/management/deer-fencing.html (last visited Aug. 12, 2024). 
     1.   Defendants’  Motion  to  Dismiss  Amended  Complaint  [Docket  No.  13]  is 
        GRANTED; 
     2.  Plaintiffs’ Amended Complaint [Docket No. 12] is DISMISSED WITH PREJUDICE; 
        and 
     3.  Plaintiffs’ Motion for Preliminary Injunction [Docket No. 18] is DENIED as moot. 
     LET JUDGMENT BE ENTERED ACCORDINGLY. 

DATED:  August 14, 2024                           dob, □□□ (deen 
at Minneapolis, Minnesota.                         JOHN R. TUNHEIM 
                                            United States District Judge 

                                    -21- 

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