2026 Membership Book FINAL

USCA4 Appeal: 25-1892

Doc: 16

Filed: 10/15/2025

Pg: 69 of 97

None remotely supports the district court’s conclusion that states may ban

contracts traded on DCMs. Finally , the district court maintained that “[i] nterpreting the CEA to

preempt state gambling laws when wagers are conducted on a DCM ” would

conflict with various federal gambling statutes. JA170. Not at all.

To start, Kalshi’s event contracts are not subject to the Wire Act or

Indian Gaming Regulatory Act (“IGRA”) . UIGEA, the federal law specifically governing internet wagering, provides that the term “bet or wager” “ does not include ” “any transaction conducted on or subject to the rules of a [DCM]

under the [CEA] .” 31 U.S.C. § 5362(1)(E) (emphasis added). UIGEA

postdates both IGRA and the Wire Act, and UIGEA’s definition is entitled “to

great weight ” in resolving the meaning of prior statutes addressing the same subject matter. Bob Jones Univ. v. United States , 461 U.S. 574, 587 n.10

(1983) (quotation omitted). Interpreting IGRA and the Wire Act to exclude

trading on DCMs would harmonize them with the CEA and UIGEA, fulfilling

the obligation to “ reconcile and harmonize ” statutes on the same subject rather than interpreting them to conflict. In re Bulldog Trucking, Inc. , 66

F.3d 1390, 1395 (4th Cir. 1995). But the district court’s interpretation does

the opposite, effectively nullifying UIGEA’s exclusion by subjecting the very

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