2026 Membership Book FINAL

Case: 25-7516, 01/23/2026, DktEntry: 33.1, Page 71 of 110

need to be “clear congressional authorization” for the CFTC to take exclu-

sive regulation of sports betting. West Virginia , 597 U.S. at 732 (internal

quotation marks omitted). Kalshi points to no such authorization.

Kalshi’s only response (Br. 60-61) is that ruling for State Defendants

would allow States to regulate commodity-futures markets. But Nevada is

not seeking to regulate interest-rate swaps or pork futures. State Defend-

ants forthrightly acknowledged that state attempts to regulate bona fide

commodity derivatives would be preempted. 1-StateSER-26; see Martin ,

793 F. Supp. 3d at 681. This case involves only Kalshi’s sports and election

contracts—classic forms of gambling that have long been regulated by the

States.

d. Kalshi’s view would require impliedly repeal- ing other important federal laws Kalshi’s view of the CEA would require finding that Congress im-

pliedly repealed other federal laws, including the Indian Gaming Regula-

tory Act (IGRA), 25 U.S.C. § 2701 et seq. , and the Wire Act, 18 U.S.C. § 1084.

Martin , 793 F. Supp. 3d at 683. There is a strong presumption against such

repeals by implication. Epic Sys. Corp. v. Lewis , 584 U.S. 497, 510 (2018).

The IGRA gives Tribes the “exclusive right” to determine whether and

to what extent to allow gaming that is permitted under federal and state

law on tribal land, 25 U.S.C. § 2701(5), and it contains a comprehensive

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