2026 Membership Book FINAL

USCA4 Appeal: 25-1892

Doc: 16

Filed: 10/15/2025

Pg: 75 of 97

whether a presumption applies. See Nazarian , 753 F.3d at 477 (“ even were

we to apply the presumption, we would find it overcome ”). But if the Court

reaches the question, the district court erred in applying the presumption,

for two reasons. First , t he district court cited the Supreme Court’s Medtronic decision for the assertion that the presumption applies in “all” preemption cases. JA157-158 (quotation omitted); see Medtronic, Inc. v. Lohr , 518 U.S. 470, 485 (1996). But, following Medtronic , the Supreme Court has squarely held that the presumption does not apply in cases like this one: Where a statute

“‘ contains an express pre-emption clause, ’ [courts] do not invoke any

presumption against pre-emption but instead ‘ focus on the plain wording of

the clause, which necessarily contains the best evidence of Congress ’ pre- emptive intent. ’” Puerto Rico v. Franklin Cal. Tax-free Tr. , 579 U.S. 115, 125 (2016) (quoting Chamber of Com. of U.S. v. Whiting , 563 U.S. 582, 594

(2011)). This Court agrees: “ [T]he best course is simply to follow as faithfully

as we can the wording of the express preemption provision, without applying a presumption one way or the other .” Air Evac EMS, Inc. v. Cheatham , 910

F.3d 751, 762 n.1 (4th Cir. 2018).

The CEA contains an express-preemption clause giving the CFTC

“ exclusive jurisdiction ” over the field of trading on DCMs. 7 U.S.C.

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