2026 Membership Book FINAL

USCA4 Appeal: 25-1892

Doc: 16

Filed: 10/15/2025

Pg: 62 of 97

jurisdiction. 7 U.S.C. § 7a-2(c)(5)(C). The district court never addressed the

Special Rule ’s reference to “ gaming ” or explained how the CFTC ’s authority

to approve or prohibit gaming contracts could be reconciled with its theory

of concurrent state authority. W here “the CFTC has jurisdiction, its power is exclusive, ” Chi. Mercantile Exch. , 883 F.2d at 548, and nothing in the CEA

allows states to retain authority to approve or prohibit trading of the very

same instruments the CFTC may unquestionably approve or prohibit.

The district court cited a different Special Rule category involving

“activity that is unlawful under any Federal or State law . ” 7 U.S.C. § 7a -

2(c)(5)(C)(i)(I). According to the court, this provision reflects an “ intent to preserve state laws ” and to allow states to regulate all contracts on DCMs

they deem unlawful. JA164. That interpretation would have dramatic

consequences; it would eliminate the uniform system Congress enacted the

1974 amendments to impose. It also misreads the Special Rule, which

provides that “ the Commission ”— not 50 different states —“may determine”

that contracts “are contrary to the public interest” if they involve activity

unlawful under state law. 7 U.S.C. § 7a-2(c)(5)(C)(i)(I). Congress thus authorized the CFTC to determine whether a contract should be prohibited.

It certainly did not allow 50 different states to substitute their own regulation

for the CFTC’s public-interest judgment. This case therefore bears no

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