Jensen v. Minnesota Board of Medical Practice

U.S. District Court, District of Minnesota

Jensen v. Minnesota Board of Medical Practice

Trial Court Opinion

                UNITED STATES DISTRICT COURT                             
                    DISTRICT OF MINNESOTA                                


Dr. Scott Jensen,                        Civ. No. 23-1689 (JWB/DTS)      

               Plaintiff,                                                

v.                                                                       

Minnesota Board of Medical Practice; Ruth                                
Martinez, Elizabeth A. Huntley, Cheryl L. Bailey,                        
John M. Manahan, Peter J. Henry, in both their  ORDER ON                 
individual and official capacities as members of  DEFENDANTS’ MOTION     
the Minnesota Board of Medical Practice; Brian  TO DISMISS               
Anderson, in his individual and official capacity                        
as a medical regulations analyst for the                                 
Minnesota Board of Medical Practice; and Jane                            
Roes 1–12 and John Does 1–4, in both their                               
individual and official capacities as members of                         
the Minnesota Board of Medical Practice,                                 

               Defendants.                                               


Douglas P. Seaton, Esq., and James V.F. Dickey, Esq., Upper Midwest Law Center, and 
Gregory James Joseph, Esq., Joseph Law Office PLLC, counsel for Plaintiff. 

David M. Cullen, Esq., and Nicholas Lienesch, Esq., Minnesota Attorney General’s 
Office, counsel for Defendants.                                           


    When public health intersected with politics, the result was this lawsuit. This case 
raises questions of what happens under the First Amendment when a physician who is 
also a political candidate makes health-related statements about a global pandemic that 
prompt public complaints and actions from the state medical licensing board.  
    Plaintiff Dr. Scott Jensen ran as the Republican candidate in the 2022 election for 
Minnesota Governor. (Doc. No. 1 (“Compl.”) ¶ 1.) Because of his qualifications as a 
licensed physician and reputation for challenging the “official narrative” around  
COVID-19, Jensen’s campaign included commentary about the pandemic and how 

Governor Walz managed the State of Minnesota’s response. Jensen spoke publicly, 
posted to social media, and appeared on television to share his views about the disease, 
treatment, and public health requirements. The Minnesota Board of Medical Practice 
received complaints about his health-related statements and behavior and invited Jensen 
to respond.                                                               
    Minnesota law requires the Board to “receive and resolve” complaints against 

licensed physicians. 
Minn. Stat. § 214.103
, subd. 2. It must discern whether a complaint 
involves a statute or rule the Board is empowered to enforce, but otherwise has discretion 
over how to initially respond. 
Id.
 It may seek additional information to determine 
jurisdiction or to clarify a complaint’s allegations, but such information gathering is not 
required. 
Id.
 Short of a full investigation or a contested case hearing, the Board may make 

preliminary attempts to resolve a complaint by writing to, speaking with, or holding a 
conference with the subject physician. 
Id.,
 subd. 6(a). If further investigation is needed, 
or if resolution could result in discipline or corrective action, the Board must involve a 
designee of the state attorney general’s office. 
Id.,
 subds. 5, 6(a). The Board may also 
reopen dismissed complaints if it receives new information or a new complaint indicating 

a pattern of behavior or conduct. 
Id.,
 subd. 8(b).                        
    Between June 2020 and October 2021, the Board sent Jensen five notices that 
summarized the complaints filed against him. (See Compl. Exs. 1–5.) One notice simply 
informed him that a complaint had been received but was already dismissed, while the 
four others invited a written response. (Id.) The final notice remained open for over a 
year, eventually leading to a conference with the Board in March 2023 to discuss the 

complaints about Jensen’s public statements on COVID-19 and patient care that it had 
received from April 2020 to June 2022. (Id. ¶¶ 216, 252–53, Exs. 5–6.)    
    None of the complaints advanced beyond the information collection phase. Jensen 
submitted written materials when requested, and he answered questions at the previously 
mentioned conference. All complaints were eventually dismissed without proceeding to a 
contested hearing or resulting in any form of corrective action. Jensen does not allege that 

the Board issued any specific instructions or guidance regarding the content of his public 
statements, suggested modifications to the way he expressed his views, or recommended 
reducing the frequency of his public engagements.                         
    Jensen now sues, claiming that the complaints and Board inquiries placed a “cloud 
of constant uncertainty” over his campaign. (Compl. ¶ 6.) He characterizes it as a 

“weaponization of a government agency,” amounting to an “ideologically driven, 
politicized government censorship apparatus which retaliated against its opponent based 
on the content of the message he espoused.” (Id. ¶¶ 7–8.) He sues the Board, its members, 
and a regulatory analyst (collectively “the Board”), claiming that the statutes authorizing 
the Board’s receipt and investigation of citizen complaints violate the First Amendment 

on their face and as applied to him.                                      
    Defendants contend that Jensen’s case should be dismissed because (1) Jensen 
lacks standing, and his claims are also moot; (2) the Board and its members are immune 
from suit; and (3) Jensen fails to state any constitutional claim.        
    Upon review, Jensen lacks standing under Article III of the Constitution because 
his Complaint does not establish the necessary injury in fact.            

                          DISCUSSION                                     
I.   Legal Standard                                                       

    To survive a motion to dismiss, a plaintiff must provide sufficient factual matter, 
accepted as true, to state a claim to relief that is plausible on its face. Ashcroft v. Iqbal, 
556 U.S. 662, 678
 (2009). This requires a complaint to contain enough factual allegations 
to raise a right to relief above the speculative level. Bell Atlantic Corp. v. Twombly, 
550 U.S. 544, 555
 (2007). It is not sufficient to merely recite the elements of a claim with 
conclusory supporting allegations devoid of factual enhancement. Iqbal, 
556 U.S. at 678
.  
    In considering a motion to dismiss, courts accept well-pled allegations as true and 
draw all reasonable inferences in the plaintiff’s favor. Schriener v. Quicken Loans, Inc., 
774 F.3d 442, 444
 (8th Cir. 2014). However, legal conclusions, unsupported conclusions, 

unwarranted inferences, and sweeping legal conclusions couched as factual allegations 
may be ignored. See Wiles v. Capitol Indemnity Corp., 
280 F.3d 868, 870
 (8th Cir. 2002). 
II.  Analysis                                                             

    Federal courts only have jurisdiction to resolve actual cases and controversies. 
U.S. Const. Art. III § 2, cl. 1. As the party invoking federal jurisdiction, Jensen has the 
burden to show that he has standing to assert his claims in federal court. See Lujan v. 
Defenders of Wildlife, 
504 U.S. 555, 561
 (1992). He must do so using the manner and 
degree of evidence required at the current stage of litigation—the motion to dismiss stage 
here. See id.; Demarais v. Gurstel Chargo, P.A., 
869 F.3d 685
, 690–91 (8th Cir. 2017). 
    To demonstrate standing, a party must allege an injury in fact, causation, and 
redressability. Mo. Roundtable for Life v. Carnahan, 
676 F.3d 665, 672
 (8th Cir. 2012).  

An injury in fact is an actual or imminent concrete and particularized invasion of a 
legally protected interest. 
Id.
 To be concrete, the injury must actually exist. Spokeo, Inc. 
v. Robins, 
578 U.S. 330, 340
 (2016). To be particularized, it must affect the plaintiff in a 
personal and individual way. 
Id.
 at 339 (quoting Lujan, 
504 U.S. at 560
 n.1). It must be 
more than a generalized grievance. See United States v. Hays, 
515 U.S. 737, 743
 (1995). 
    Jensen must show standing for each of his claims and each form of relief he seeks. 

See TransUnion LLC v. Ramirez, 
594 U.S. 413, 431
 (2021) (collecting cases).  
         1.   First Amendment claims                                     
    Jensen’s core claim is that the Board violated his First Amendment right to free 
speech. Two types of injuries can confer standing to seek First Amendment relief. See 
Missourians for Fiscal Accountability v. Klahr, 
830 F.3d 789, 794
 (8th Cir. 2016). The 

first is when a plaintiff alleges “an intention to engage in a course of conduct arguably 
affected with a constitutional interest, but proscribed by a statute, and there exists a 
credible threat of prosecution thereunder.” 
Id.
 (quoting Babbitt v. Farm Workers, 
442 U.S. 289, 298
 (1979)). The second is when a plaintiff self-censors. 
Id.
 Self-censoring 
occurs when a plaintiff alleges he “would like to engage in arguably protected speech, but 

that he is chilled from doing so by the existence of the statute.” 281 Care Comm. v. 
Arneson, 
638 F.3d 621, 627
 (8th Cir. 2011). The plaintiff “must present more than 
allegations of a subjective chill,” however, and must allege a “specific present objective 
harm or a threat of specific future harm” to establish standing. Eckles v. City of Corydon, 
341 F.3d 762, 767
 (8th Cir. 2003); see also Thompson v. Adams, 
268 F.3d 609
, 614 (8th 
Cir. 2001) (finding no First Amendment retaliation injury where the plaintiffs offered no 

evidence of actual or potential inhibitory effect on speech). Jensen does not plead an 
actual or imminent injury of any kind.                                    
    Jensen’s Complaint does not set forth how his speech was or remains inhibited. 
Standing requires allegations that plausibly show there has been, or will be, a chilling 
effect on Jensen’s speech, and that chilling effect must be objectively reasonable. See 
Zanders v. Swanson, 
573 F.3d 591
, 593–94 (8th Cir. 2009) (stating that “chilling effect 

alone may constitute injury,” yet “the chilling effect . . . must be objectively reasonable”). 
Conclusory allegations that the Board intended to chill Jensen’s speech and that the 
Board’s actions “would chill a person of ordinary firmness” are insufficient because they 
do not establish a concrete or particularized injury to Jensen himself.   
    Jensen’s reporting to the Board that he felt politically targeted and that the 

anonymous complaints had an “ongoing chilling and suppressing effect” (see Compl.  
¶¶ 92, 118–19, 122) are insufficient to establish standing. Jensen does not allege that he 
ever refrained from speaking when he otherwise would have, or spoke less fully on the 
occasions that he did speak. In fact, the Complaint includes multiple examples of the 
opposite—of Jensen continuing to speak about COVID-19 in various forums. (See id.  

¶¶ 102, 133, 152–53, 188, 236.)                                           
    For example, Jensen alleges that by the fall of 2020—which was after two Board 
complaints had been lodged, investigated, and dismissed—his public statements had 
earned him “a reputation as someone who was unafraid to challenge the official health 
care narrative.” (Id. ¶ 127.)                                             
    He alleges that he continued speaking in the years that followed:    

 •  “Throughout the Spring and Summer of 2021, Dr. Jensen continued to speak his 
    perspective about the government response to COVID-19 and speak as an 
    independent voice who questioned the dominant political narrative in the State of 
    Minnesota and nationwide.” (Id. ¶ 146.)                              

 •  “Along these lines, Dr. Jensen has written affidavits connected to lawsuits across 
    several states, providing his opinion on COVID-19 policies regarding subjects 
    such as mask mandates for children and adults without exemptions, and business 
    and church closures. His public comments and opinions in this area led to his 
    participation in a lawsuit filed in U.S. District Court in the Northern District of 
    Alabama.” (Id. ¶ 147.)                                               

 •  “Dr. Jensen again made national news in September, 2021 when he publicly 
    voiced his opinion on a social media video challenging a newly-announced 
    Executive Order which would compel 100 million Americans to take a COVID-19 
    injection . . . .” (Id. ¶ 171.)                                      

 •  “Plaintiff has made a number of political statements about COVID-19 and the 
    government response thereto over the course of several years, as a Minnesota 
    Senator, as a private citizen, and as a major-party nominee for Governor of 
    Minnesota.” (Id. ¶ 258.)                                             
    Jensen has not alleged when or in what context the Board’s investigations 
prevented him from speaking on topics like those that prompted public complaints 
against him. Nor has he alleged, credibly or not, that some future speech of his would 
prompt future complaints and investigations that would chill his speech when previous 
investigations did not. Instead, the allegations as pled reveal that Jensen’s speech was not 
chilled. His speech, both in frequency and apparent temperature, remained steady, 
regardless of Board receipt, investigation, and resolution of complaints. 
    Because Jensen has not plausibly alleged any objectively reasonable chilling of his 
speech, he has not set forth a concrete and particularized First Amendment injury. He 

therefore lacks standing for his First Amendment claims.                  
         2.   Facial challenges                                          
    Although Jensen’s Complaint is overwhelmingly focused on his as-applied claims, 
he also purports to challenge certain Minnesota statutes as unconstitutional on their face. 
When asserting a facial challenge, a plaintiff must still satisfy the “normal requirements” 
of Article III standing. Final Exit Network, Inc. v. Ellison, 
370 F. Supp. 3d 995, 1009
 (D. 

Minn. 2019) (citing Mosby v. Ligon, 
418 F.3d 927
, 932–33 (8th Cir. 2005)). Accordingly, 
Jensen’s failure to plead standing for his as-applied challenge eliminates standing for any 
facial challenge. See Renne v. Geary, 
501 U.S. 312, 324
 (1991) (“It is not the usual 
judicial practice, . . . nor do we consider it generally desirable, to proceed to an 
overbreadth issue unnecessarily—that is, before it is determined that the statute would be 

valid as applied.”); Mosby, 
418 F.3d at 933
 (finding no standing for attorney to bring 
facial challenge to the rules of professional conduct without also challenging their 
application to herself). Jensen lacks standing for his facial challenges. 
    Standing for a facial overbreadth claim requires setting forth a significant 
difference between the as-applied claim and the facially overbroad claim. See Final Exit 

Network, 
370 F. Supp. 3d at 1014
. For a federal court to entertain such a claim, Jensen 
must identify how third parties would be affected by the statute differently from himself. 
See 
id.
 The terms “overbroad” and “vague” appear once in the Complaint, but not as a 
challenge to any statute. Jensen argues overbreadth and vagueness in his opposition brief, 
but he cannot expand his Complaint through briefing. See Northland Baptist Church of 
St. Paul, Minn. v. Walz, 
530 F. Supp. 3d 790
, 814 (D. Minn. 2021). Jensen alleges no 

unconstitutional scenarios beyond his own case. Therefore, he lacks standing for a facial 
overbreadth challenge.                                                    
         3.   Unconstitutional conditions claim                          
    Jensen’s failure to adequately plead a First Amendment injury also eliminates 
standing for his unconstitutional conditions claim. See Parents Protecting Our Child., UA 
v. Eau Claire Area Sch. Dist., Wis., 
657 F. Supp. 3d 1161
, 1174 (W.D. Wis. 2023) 

(stating the unconstitutional conditions doctrine “does not give rise to a constitutional 
claim in its own right; the condition must actually cause a violation of a substantive 
[constitutional] right”); see also Rumsfeld v. F. for Acad. & Institutional Rts., Inc., 
547 U.S. 47, 60
 (2006) (finding a statute did not amount to an unconstitutional condition 
where the First Amendment would not prevent imposing the statutory requirement). 

Because Jensen has not pled a First Amendment injury, he lacks standing for a claim that 
requires him to show that a government-imposed condition caused such an injury. 
         4.   Viewpoint discrimination, equal protection claims          
    Jensen similarly lacks standing for his claims of viewpoint discrimination and 
“class of one” equal protection. To the extent that Jensen alleges harm on the basis of the 

Board violating his free speech rights but not others’ rights, he has not pled a First 
Amendment injury as explained above. See Zanders, 
573 F.3d at 594
 (stating that First 
Amendment injury requires objectively reasonable chilling effect); cf. Christa McAuliffe 
Intermediate Sch. PTO, Inc. v. DeBlasio, 
627 F. Supp. 3d 253
, 262 (S.D.N.Y. 2022) 
(stating that both discriminatory effect and discriminatory purpose are required for an 
equal protection claim). Jensen’s lack of First Amendment injury makes his differential 

treatment theories more like “generalized grievances” or “bare procedural violations,” 
which do not qualify as injuries in fact. See Carney v. Adams, 
592 U.S. 53, 58
 (2020); 
Spokeo, 
578 U.S. at 341
.                                                  
    Though no conclusion is reached on this point, the requirement that licensed 
physicians comply with medical board requests for information following a complaint on 
medical matters is perhaps not a harm at all, let alone a harm unique to Jensen. As 

reflected by the Board’s role in qualifying and overseeing physician practice, the Board is 
authorized to regulate the medical profession to safeguard the public health and welfare. 
All licensed physicians consent to the Board’s regulatory framework as an important part 
of what being a licensed physician inherently means. The Board is required by law to 
resolve complaints, and it may request a response from the subject physician to determine 

jurisdiction or clarify the nature of the allegations. See 
Minn. Stat. § 214.103
, subd. 2. 
Practicing medicine is a privilege. Any burden on Jensen to respond to the Board’s 
requests upon receipt of complaints appears de minimis and an expected cooperation in a 
regulated profession that he voluntarily joined.                          
    If Jensen’s claim of harm is alleged differential treatment within the Board’s 

investigation process, he again fails to plead an actual injury. His only allegations about 
how the Board treated other physicians are his conclusory and formulaic allegations 
based upon “information and belief.” “In the post-Twombly and Iqbal era, . . . merely 
pleading on information and belief, without more, is insufficient to survive a motion to 
dismiss for failure to state a claim.” Kampschroer v. Anoka Cnty., 
57 F. Supp. 3d 1124, 1143
 (D. Minn. 2014); see also Ahern Rentals, Inc. v. EquipmentShare.com, Inc., 
59 F.4th 948
, 954 (8th Cir. 2023).                                           
    As a result, Jensen has not plausibly pled that the Board treated physicians with 
different views more favorably or responded differently to similar public complaints 
involving others. Jensen’s allegations that the Board departed from its policy on the use 
of social media information are unavailing when plausible allegations of how the policy 
operated in other cases are lacking. Jensen therefore has not shown standing for his 

viewpoint discrimination and equal protection claims.                     
    Without standing for his claims, Jensen’s Complaint must be dismissed for lack of 
federal jurisdiction. Defendants’ remaining arguments on sovereign immunity, qualified 
immunity, and failure to state a claim are beyond the scope of this Order.  

ORDER

    IT IS HEREBY ORDERED that Defendants’ Motion to Dismiss (Doc. No. 26) 
is GRANTED, and Plaintiff’s Complaint (Doc. No. 1) is DISMISSED WITHOUT   
PREJUDICE for lack of standing. Plaintiff may file an Amended Complaint within 21 
days from the date of this Order. If no Amended Complaint is filed, judgment will be 
entered, and this matter will be closed.                                  


Date: March 29, 2024            s/ Jerry W. Blackwell                     
                               JERRY W. BLACKWELL                        
                               United States District Judge              

Trial Court Opinion

                UNITED STATES DISTRICT COURT                             
                    DISTRICT OF MINNESOTA                                


Dr. Scott Jensen,                        Civ. No. 23-1689 (JWB/DTS)      

               Plaintiff,                                                

v.                                                                       

Minnesota Board of Medical Practice; Ruth                                
Martinez, Elizabeth A. Huntley, Cheryl L. Bailey,                        
John M. Manahan, Peter J. Henry, in both their  ORDER ON                 
individual and official capacities as members of  DEFENDANTS’ MOTION     
the Minnesota Board of Medical Practice; Brian  TO DISMISS               
Anderson, in his individual and official capacity                        
as a medical regulations analyst for the                                 
Minnesota Board of Medical Practice; and Jane                            
Roes 1–12 and John Does 1–4, in both their                               
individual and official capacities as members of                         
the Minnesota Board of Medical Practice,                                 

               Defendants.                                               


Douglas P. Seaton, Esq., and James V.F. Dickey, Esq., Upper Midwest Law Center, and 
Gregory James Joseph, Esq., Joseph Law Office PLLC, counsel for Plaintiff. 

David M. Cullen, Esq., and Nicholas Lienesch, Esq., Minnesota Attorney General’s 
Office, counsel for Defendants.                                           


    When public health intersected with politics, the result was this lawsuit. This case 
raises questions of what happens under the First Amendment when a physician who is 
also a political candidate makes health-related statements about a global pandemic that 
prompt public complaints and actions from the state medical licensing board.  
    Plaintiff Dr. Scott Jensen ran as the Republican candidate in the 2022 election for 
Minnesota Governor. (Doc. No. 1 (“Compl.”) ¶ 1.) Because of his qualifications as a 
licensed physician and reputation for challenging the “official narrative” around  
COVID-19, Jensen’s campaign included commentary about the pandemic and how 

Governor Walz managed the State of Minnesota’s response. Jensen spoke publicly, 
posted to social media, and appeared on television to share his views about the disease, 
treatment, and public health requirements. The Minnesota Board of Medical Practice 
received complaints about his health-related statements and behavior and invited Jensen 
to respond.                                                               
    Minnesota law requires the Board to “receive and resolve” complaints against 

licensed physicians. 
Minn. Stat. § 214.103
, subd. 2. It must discern whether a complaint 
involves a statute or rule the Board is empowered to enforce, but otherwise has discretion 
over how to initially respond. 
Id.
 It may seek additional information to determine 
jurisdiction or to clarify a complaint’s allegations, but such information gathering is not 
required. 
Id.
 Short of a full investigation or a contested case hearing, the Board may make 

preliminary attempts to resolve a complaint by writing to, speaking with, or holding a 
conference with the subject physician. 
Id.,
 subd. 6(a). If further investigation is needed, 
or if resolution could result in discipline or corrective action, the Board must involve a 
designee of the state attorney general’s office. 
Id.,
 subds. 5, 6(a). The Board may also 
reopen dismissed complaints if it receives new information or a new complaint indicating 

a pattern of behavior or conduct. 
Id.,
 subd. 8(b).                        
    Between June 2020 and October 2021, the Board sent Jensen five notices that 
summarized the complaints filed against him. (See Compl. Exs. 1–5.) One notice simply 
informed him that a complaint had been received but was already dismissed, while the 
four others invited a written response. (Id.) The final notice remained open for over a 
year, eventually leading to a conference with the Board in March 2023 to discuss the 

complaints about Jensen’s public statements on COVID-19 and patient care that it had 
received from April 2020 to June 2022. (Id. ¶¶ 216, 252–53, Exs. 5–6.)    
    None of the complaints advanced beyond the information collection phase. Jensen 
submitted written materials when requested, and he answered questions at the previously 
mentioned conference. All complaints were eventually dismissed without proceeding to a 
contested hearing or resulting in any form of corrective action. Jensen does not allege that 

the Board issued any specific instructions or guidance regarding the content of his public 
statements, suggested modifications to the way he expressed his views, or recommended 
reducing the frequency of his public engagements.                         
    Jensen now sues, claiming that the complaints and Board inquiries placed a “cloud 
of constant uncertainty” over his campaign. (Compl. ¶ 6.) He characterizes it as a 

“weaponization of a government agency,” amounting to an “ideologically driven, 
politicized government censorship apparatus which retaliated against its opponent based 
on the content of the message he espoused.” (Id. ¶¶ 7–8.) He sues the Board, its members, 
and a regulatory analyst (collectively “the Board”), claiming that the statutes authorizing 
the Board’s receipt and investigation of citizen complaints violate the First Amendment 

on their face and as applied to him.                                      
    Defendants contend that Jensen’s case should be dismissed because (1) Jensen 
lacks standing, and his claims are also moot; (2) the Board and its members are immune 
from suit; and (3) Jensen fails to state any constitutional claim.        
    Upon review, Jensen lacks standing under Article III of the Constitution because 
his Complaint does not establish the necessary injury in fact.            

                          DISCUSSION                                     
I.   Legal Standard                                                       

    To survive a motion to dismiss, a plaintiff must provide sufficient factual matter, 
accepted as true, to state a claim to relief that is plausible on its face. Ashcroft v. Iqbal, 
556 U.S. 662, 678
 (2009). This requires a complaint to contain enough factual allegations 
to raise a right to relief above the speculative level. Bell Atlantic Corp. v. Twombly, 
550 U.S. 544, 555
 (2007). It is not sufficient to merely recite the elements of a claim with 
conclusory supporting allegations devoid of factual enhancement. Iqbal, 
556 U.S. at 678
.  
    In considering a motion to dismiss, courts accept well-pled allegations as true and 
draw all reasonable inferences in the plaintiff’s favor. Schriener v. Quicken Loans, Inc., 
774 F.3d 442, 444
 (8th Cir. 2014). However, legal conclusions, unsupported conclusions, 

unwarranted inferences, and sweeping legal conclusions couched as factual allegations 
may be ignored. See Wiles v. Capitol Indemnity Corp., 
280 F.3d 868, 870
 (8th Cir. 2002). 
II.  Analysis                                                             

    Federal courts only have jurisdiction to resolve actual cases and controversies. 
U.S. Const. Art. III § 2, cl. 1. As the party invoking federal jurisdiction, Jensen has the 
burden to show that he has standing to assert his claims in federal court. See Lujan v. 
Defenders of Wildlife, 
504 U.S. 555, 561
 (1992). He must do so using the manner and 
degree of evidence required at the current stage of litigation—the motion to dismiss stage 
here. See id.; Demarais v. Gurstel Chargo, P.A., 
869 F.3d 685
, 690–91 (8th Cir. 2017). 
    To demonstrate standing, a party must allege an injury in fact, causation, and 
redressability. Mo. Roundtable for Life v. Carnahan, 
676 F.3d 665, 672
 (8th Cir. 2012).  

An injury in fact is an actual or imminent concrete and particularized invasion of a 
legally protected interest. 
Id.
 To be concrete, the injury must actually exist. Spokeo, Inc. 
v. Robins, 
578 U.S. 330, 340
 (2016). To be particularized, it must affect the plaintiff in a 
personal and individual way. 
Id.
 at 339 (quoting Lujan, 
504 U.S. at 560
 n.1). It must be 
more than a generalized grievance. See United States v. Hays, 
515 U.S. 737, 743
 (1995). 
    Jensen must show standing for each of his claims and each form of relief he seeks. 

See TransUnion LLC v. Ramirez, 
594 U.S. 413, 431
 (2021) (collecting cases).  
         1.   First Amendment claims                                     
    Jensen’s core claim is that the Board violated his First Amendment right to free 
speech. Two types of injuries can confer standing to seek First Amendment relief. See 
Missourians for Fiscal Accountability v. Klahr, 
830 F.3d 789, 794
 (8th Cir. 2016). The 

first is when a plaintiff alleges “an intention to engage in a course of conduct arguably 
affected with a constitutional interest, but proscribed by a statute, and there exists a 
credible threat of prosecution thereunder.” 
Id.
 (quoting Babbitt v. Farm Workers, 
442 U.S. 289, 298
 (1979)). The second is when a plaintiff self-censors. 
Id.
 Self-censoring 
occurs when a plaintiff alleges he “would like to engage in arguably protected speech, but 

that he is chilled from doing so by the existence of the statute.” 281 Care Comm. v. 
Arneson, 
638 F.3d 621, 627
 (8th Cir. 2011). The plaintiff “must present more than 
allegations of a subjective chill,” however, and must allege a “specific present objective 
harm or a threat of specific future harm” to establish standing. Eckles v. City of Corydon, 
341 F.3d 762, 767
 (8th Cir. 2003); see also Thompson v. Adams, 
268 F.3d 609
, 614 (8th 
Cir. 2001) (finding no First Amendment retaliation injury where the plaintiffs offered no 

evidence of actual or potential inhibitory effect on speech). Jensen does not plead an 
actual or imminent injury of any kind.                                    
    Jensen’s Complaint does not set forth how his speech was or remains inhibited. 
Standing requires allegations that plausibly show there has been, or will be, a chilling 
effect on Jensen’s speech, and that chilling effect must be objectively reasonable. See 
Zanders v. Swanson, 
573 F.3d 591
, 593–94 (8th Cir. 2009) (stating that “chilling effect 

alone may constitute injury,” yet “the chilling effect . . . must be objectively reasonable”). 
Conclusory allegations that the Board intended to chill Jensen’s speech and that the 
Board’s actions “would chill a person of ordinary firmness” are insufficient because they 
do not establish a concrete or particularized injury to Jensen himself.   
    Jensen’s reporting to the Board that he felt politically targeted and that the 

anonymous complaints had an “ongoing chilling and suppressing effect” (see Compl.  
¶¶ 92, 118–19, 122) are insufficient to establish standing. Jensen does not allege that he 
ever refrained from speaking when he otherwise would have, or spoke less fully on the 
occasions that he did speak. In fact, the Complaint includes multiple examples of the 
opposite—of Jensen continuing to speak about COVID-19 in various forums. (See id.  

¶¶ 102, 133, 152–53, 188, 236.)                                           
    For example, Jensen alleges that by the fall of 2020—which was after two Board 
complaints had been lodged, investigated, and dismissed—his public statements had 
earned him “a reputation as someone who was unafraid to challenge the official health 
care narrative.” (Id. ¶ 127.)                                             
    He alleges that he continued speaking in the years that followed:    

 •  “Throughout the Spring and Summer of 2021, Dr. Jensen continued to speak his 
    perspective about the government response to COVID-19 and speak as an 
    independent voice who questioned the dominant political narrative in the State of 
    Minnesota and nationwide.” (Id. ¶ 146.)                              

 •  “Along these lines, Dr. Jensen has written affidavits connected to lawsuits across 
    several states, providing his opinion on COVID-19 policies regarding subjects 
    such as mask mandates for children and adults without exemptions, and business 
    and church closures. His public comments and opinions in this area led to his 
    participation in a lawsuit filed in U.S. District Court in the Northern District of 
    Alabama.” (Id. ¶ 147.)                                               

 •  “Dr. Jensen again made national news in September, 2021 when he publicly 
    voiced his opinion on a social media video challenging a newly-announced 
    Executive Order which would compel 100 million Americans to take a COVID-19 
    injection . . . .” (Id. ¶ 171.)                                      

 •  “Plaintiff has made a number of political statements about COVID-19 and the 
    government response thereto over the course of several years, as a Minnesota 
    Senator, as a private citizen, and as a major-party nominee for Governor of 
    Minnesota.” (Id. ¶ 258.)                                             
    Jensen has not alleged when or in what context the Board’s investigations 
prevented him from speaking on topics like those that prompted public complaints 
against him. Nor has he alleged, credibly or not, that some future speech of his would 
prompt future complaints and investigations that would chill his speech when previous 
investigations did not. Instead, the allegations as pled reveal that Jensen’s speech was not 
chilled. His speech, both in frequency and apparent temperature, remained steady, 
regardless of Board receipt, investigation, and resolution of complaints. 
    Because Jensen has not plausibly alleged any objectively reasonable chilling of his 
speech, he has not set forth a concrete and particularized First Amendment injury. He 

therefore lacks standing for his First Amendment claims.                  
         2.   Facial challenges                                          
    Although Jensen’s Complaint is overwhelmingly focused on his as-applied claims, 
he also purports to challenge certain Minnesota statutes as unconstitutional on their face. 
When asserting a facial challenge, a plaintiff must still satisfy the “normal requirements” 
of Article III standing. Final Exit Network, Inc. v. Ellison, 
370 F. Supp. 3d 995, 1009
 (D. 

Minn. 2019) (citing Mosby v. Ligon, 
418 F.3d 927
, 932–33 (8th Cir. 2005)). Accordingly, 
Jensen’s failure to plead standing for his as-applied challenge eliminates standing for any 
facial challenge. See Renne v. Geary, 
501 U.S. 312, 324
 (1991) (“It is not the usual 
judicial practice, . . . nor do we consider it generally desirable, to proceed to an 
overbreadth issue unnecessarily—that is, before it is determined that the statute would be 

valid as applied.”); Mosby, 
418 F.3d at 933
 (finding no standing for attorney to bring 
facial challenge to the rules of professional conduct without also challenging their 
application to herself). Jensen lacks standing for his facial challenges. 
    Standing for a facial overbreadth claim requires setting forth a significant 
difference between the as-applied claim and the facially overbroad claim. See Final Exit 

Network, 
370 F. Supp. 3d at 1014
. For a federal court to entertain such a claim, Jensen 
must identify how third parties would be affected by the statute differently from himself. 
See 
id.
 The terms “overbroad” and “vague” appear once in the Complaint, but not as a 
challenge to any statute. Jensen argues overbreadth and vagueness in his opposition brief, 
but he cannot expand his Complaint through briefing. See Northland Baptist Church of 
St. Paul, Minn. v. Walz, 
530 F. Supp. 3d 790
, 814 (D. Minn. 2021). Jensen alleges no 

unconstitutional scenarios beyond his own case. Therefore, he lacks standing for a facial 
overbreadth challenge.                                                    
         3.   Unconstitutional conditions claim                          
    Jensen’s failure to adequately plead a First Amendment injury also eliminates 
standing for his unconstitutional conditions claim. See Parents Protecting Our Child., UA 
v. Eau Claire Area Sch. Dist., Wis., 
657 F. Supp. 3d 1161
, 1174 (W.D. Wis. 2023) 

(stating the unconstitutional conditions doctrine “does not give rise to a constitutional 
claim in its own right; the condition must actually cause a violation of a substantive 
[constitutional] right”); see also Rumsfeld v. F. for Acad. & Institutional Rts., Inc., 
547 U.S. 47, 60
 (2006) (finding a statute did not amount to an unconstitutional condition 
where the First Amendment would not prevent imposing the statutory requirement). 

Because Jensen has not pled a First Amendment injury, he lacks standing for a claim that 
requires him to show that a government-imposed condition caused such an injury. 
         4.   Viewpoint discrimination, equal protection claims          
    Jensen similarly lacks standing for his claims of viewpoint discrimination and 
“class of one” equal protection. To the extent that Jensen alleges harm on the basis of the 

Board violating his free speech rights but not others’ rights, he has not pled a First 
Amendment injury as explained above. See Zanders, 
573 F.3d at 594
 (stating that First 
Amendment injury requires objectively reasonable chilling effect); cf. Christa McAuliffe 
Intermediate Sch. PTO, Inc. v. DeBlasio, 
627 F. Supp. 3d 253
, 262 (S.D.N.Y. 2022) 
(stating that both discriminatory effect and discriminatory purpose are required for an 
equal protection claim). Jensen’s lack of First Amendment injury makes his differential 

treatment theories more like “generalized grievances” or “bare procedural violations,” 
which do not qualify as injuries in fact. See Carney v. Adams, 
592 U.S. 53, 58
 (2020); 
Spokeo, 
578 U.S. at 341
.                                                  
    Though no conclusion is reached on this point, the requirement that licensed 
physicians comply with medical board requests for information following a complaint on 
medical matters is perhaps not a harm at all, let alone a harm unique to Jensen. As 

reflected by the Board’s role in qualifying and overseeing physician practice, the Board is 
authorized to regulate the medical profession to safeguard the public health and welfare. 
All licensed physicians consent to the Board’s regulatory framework as an important part 
of what being a licensed physician inherently means. The Board is required by law to 
resolve complaints, and it may request a response from the subject physician to determine 

jurisdiction or clarify the nature of the allegations. See 
Minn. Stat. § 214.103
, subd. 2. 
Practicing medicine is a privilege. Any burden on Jensen to respond to the Board’s 
requests upon receipt of complaints appears de minimis and an expected cooperation in a 
regulated profession that he voluntarily joined.                          
    If Jensen’s claim of harm is alleged differential treatment within the Board’s 

investigation process, he again fails to plead an actual injury. His only allegations about 
how the Board treated other physicians are his conclusory and formulaic allegations 
based upon “information and belief.” “In the post-Twombly and Iqbal era, . . . merely 
pleading on information and belief, without more, is insufficient to survive a motion to 
dismiss for failure to state a claim.” Kampschroer v. Anoka Cnty., 
57 F. Supp. 3d 1124, 1143
 (D. Minn. 2014); see also Ahern Rentals, Inc. v. EquipmentShare.com, Inc., 
59 F.4th 948
, 954 (8th Cir. 2023).                                           
    As a result, Jensen has not plausibly pled that the Board treated physicians with 
different views more favorably or responded differently to similar public complaints 
involving others. Jensen’s allegations that the Board departed from its policy on the use 
of social media information are unavailing when plausible allegations of how the policy 
operated in other cases are lacking. Jensen therefore has not shown standing for his 

viewpoint discrimination and equal protection claims.                     
    Without standing for his claims, Jensen’s Complaint must be dismissed for lack of 
federal jurisdiction. Defendants’ remaining arguments on sovereign immunity, qualified 
immunity, and failure to state a claim are beyond the scope of this Order.  

ORDER

    IT IS HEREBY ORDERED that Defendants’ Motion to Dismiss (Doc. No. 26) 
is GRANTED, and Plaintiff’s Complaint (Doc. No. 1) is DISMISSED WITHOUT   
PREJUDICE for lack of standing. Plaintiff may file an Amended Complaint within 21 
days from the date of this Order. If no Amended Complaint is filed, judgment will be 
entered, and this matter will be closed.                                  


Date: March 29, 2024            s/ Jerry W. Blackwell                     
                               JERRY W. BLACKWELL                        
                               United States District Judge              

Reference

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