It never has. The NFL instituted a rule stating that the host city must have an average temperature of 50 degrees or more, otherwise it must be domed. There have only been two instances of the game being played above the mason-dixon line, Minnesota and Detroit, all played in domes. It did, however, snow in Detroit while the Super Bowl was about to be played, but that is a technicallity. It's always snowing somewhere, right? That's like saying it's happy hour somewhere to justify your drink.
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