For any estimator in a metric parameter space, by the triangle inequality. Average the two risk functions and replace their probability density functions by their minimum. This proves . The overlap equals one minus total variation distance. The same proof applies to squared error for a real-valued statistical functional of the parameter, without requiring that functional to be injective.
For estimating the expected value over all continuous probability density functions on , compare and . Their means differ by , and . The chi-squared divergence of product measures bounds joint total variation distance by . The metric squared-loss two-point bound then gives the displayed uniform minimax risk lower bound.
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