2026 Membership Book FINAL

USCA4 Appeal: 25-1892

Doc: 16

Filed: 10/15/2025

Pg: 71 of 97

where they would subject an entity to “conflicting standards.” Gordon v. New York Stock Exch., Inc. , 422 U.S. 659, 689 (1975); see also Scalia & Garner, supra , at 328 (a later statute supersedes an earlier one where their

provisions “are in irreconcilable conflict ”).

The district court cited PASPA, opining that Congress would not have

intended to “ override ” state sports-betting laws in 1974 and 2010 because it

was “ largely illegal federally to engage in sports gambling ” before the Supreme Court’s 2018 Murphy decision. JA169-170. PASPA was a

limitation on state legislatures; it did not speak to what contracts could be

offered on DCMs. But PASPA no doubt explains why no DCM offered sports-

event contracts until recently; DCMs likely expected that the CFTC would

deem such contracts contrary to the public interest when most states

prohibited sports betting. The rapid legalization and growth of sports betting

across the country since 2018 helps explain why the CFTC has allowed

sports-event contracts in this very different landscape. C. The District Court Erred In Rejecting Conflict Preemption. The district court’s grounds for rejecting c onflict preemption are equally unpersuasive and supply an independent basis to reverse. First, the district court dismissed the conflict between Maryland and

federal law, suggesting that any conflict arose from “Kalshi’s desire not to

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