Case 2:25-cv-01541-APG-DJA Document 32 Filed 09/30/25 Page 18 of 21
Congress has declared its commitment to supporting Tribal self-determination and self-
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governance, stating:
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The Congress declares its commitment to the maintenance of the Federal Government’s unique and continuing relationship with, and responsibility to, individual Indian tribes and to the Indian people as a whole through the establishment of a meaningful Indian self- determination policy … [and] to supporting and assisting Indian tribes in the development of strong and stable tribal governments, capable of administering quality programs and developing the economies of their respective communities.
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25 U.S.C. § 5302(b). The Executive Branch has consistently affirmed this policy. See e.g. , Exec.
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Order No. 13175, § 2(c), 65 Fed. Reg. 67,249, 67,249 (Nov. 6, 2000); Exec. Order No. 13647, §
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1(a), 78 Fed. Reg. 39,539, 39,539 (June 26, 2013).
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In Cabazon , the Supreme Court recognized the importance of “the congressional goal of
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Indian self-government, including its overriding goal of encouraging tribal self-sufficiency and
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economic development[,]” and noted that federal agencies “ha[ve] sought to implement these
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policies by promoting tribal bingo enterprises.” 480 U.S. at 216–17 (internal quotations omitted).
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It also acknowledged that tribal casinos often provide “the sole source of revenues for the
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operation of the tribal governments and the provision of tribal services” and that, in some
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instances, tribal casinos “are also the major sources of employment on the reservations.” Id. at
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218–19. Following Cabazon , Congress declared in IGRA that “[t]he purpose of [IGRA] is … to
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provide a statutory basis for the operation of gaming by Indian tribes as a means of promoting
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tribal economic development, self-sufficiency, and strong tribal governments ….” 25 U.S.C.
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§ 2702(1).
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Robinhood tramples upon established federal Indian policy by usurping the rights of tribes
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to regulate gaming on Indian land and benefit from such gaming. IGRA mandates that tribes “have
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the exclusive right to regulate gaming on Indian lands,” and that sports betting is “lawful on Indian
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lands only if … conducted in conformance with a Tribal-State compact….” 25 U.S.C. §§ 2701(5),
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2710(d)(1)(C); see 25 C.F.R. § 502.4(c). Robinhood violates this exclusive right. Robinhood’s
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intrusion is particularly dangerous because it does not comply with any gaming regulations that
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