2026 Membership Book FINAL

USCA4 Appeal: 25-1892

Doc: 16

Filed: 10/15/2025

Pg: 59 of 97

Congress in 1974 just as unquestionably intended to preempt such gambling

laws when it granted the CFTC “exclusive jurisdiction” to regulate trading on

those exchanges. It is inconceivable that, despite having “field -preemptive

intent” in 1974, JA159, Congress silently intended to allow states to apply

their gambling laws to DCMs. And it is equally inconceivable that Congress

in Dodd-Frank intended to allow states to ban trading on DCMs as gambling

even though, four years earlier, Congress in UIGEA provided that state

gambling laws “ do[] not include ” “any transac tion conducted on or subject

to the rules of a [DCM] under the [CEA].” 31 U.S.C. § 5362(1)(E).

The district court’s conclusion that states may enforce their gambling

laws against DCMs would have radical repercussions. Many states define gambling sufficiently broadly to permit regulation of any financial position on an uncertain outcome. See N.J. Rev. Stat. § 2C:37-1(b) (defining

gambling as “staking or risking something of value upon … a future

contingent event”); N.Y. Penal L. § 225.00(2) (same); Nev. Rev. Stat. § 463.0193 (regulating all entities “accepting wagers on sporting events or other events ” ) (emphasis added). If, as the district court maintained, states remain free to apply their gambling laws even to DCMs, states would be free to regulate all event contracts, or even all futures contracts — which, after all,

can readily be characterized as staking something of value on a future

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