USCA4 Appeal: 25-1892
Doc: 16
Filed: 10/15/2025
Pg: 47 of 97
Raimondo , 603 U.S. 369, 402 (2024) (courts may account for an agency’s
“body of experience and informed judgment” in interpreting a statute
(citation omitted)).
5. While this Court need not consider legislative history given the clear
statutory text and context, legislative history eliminates any doubt about
preemption. Congress emphasized in the lead-up to the 1974 amendments
that it sought to “avoid unnecessary, overlapping and duplicative regulation” in the derivatives markets. Ken Roberts , 276 F.3d at 588 (citation omitted).
The Senate understood that the proposed amendments would bring “the
futures markets” “ under Federal regulation” because “different State laws would just lead to total chaos.” Senate Hearings at 249, 685 (statements of Sen. Clark). Drafters reiterated that regulation should be uniform with exchanges “ under the same set of rules.” H.R. Rep. No. 93-975, at 76 (emphasis added). And the conference report to the 1974 amendments emphasized Congress’s desire to “ preempt the field insofar as futures regulation is concerned.” H.R. Rep. No. 93-1383 at 35 (emphasis added); see Garcia v. United States, 469 U.S. 70, 76 (1984) (when resort to legislative
history is warranted, committee reports are the “authoritative source”).
Legislative history further underscores that when Congress returned to
the CEA after 1974, it understood that the 1974 amendments had already
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