2026 Membership Book FINAL

Case 1:25-cv-01283-ABA Document 26 Filed 05/09/25 Page 22 of 36

the operation of gaming by Indian [T]ribes as a means of promoting tribal economic development,

self- sufficiency, and strong tribal governments.” 25 U.S.C. § 2702(1) . Tribes often receive a

substantial degree of exclusivity to offer gaming, including sports betting, as a benefit of their

bargain in these compacts. See Matthew L.M. Fletcher, Bringing Balance to Indian Gaming , 44

Harv. J. on Legis. 39, 75 & n.243 (2007). Just like the Wire Act, if this court deems sports gaming

contracts to be swaps, it would be eviscerating the IGRA as well.

ii.

The Specific Governs the General.

“The specific governs the general,” especially when, as here, “a general permission

or prohibition [ i.e. , the CEA’s definition of ‘swap’] is contradicted by a specific prohibition or

permission [ i.e. , the Wire Act’s express prohibition against interstate gambling on sports or

IGRA’s express prohibition against Class III gaming on tribal lands absent complia nce with the

three requirements in 25 U.S.C. § 2710(d)(1) ].” RadLAX Gateway Hotel, LLC v. Amalgamated

Bank , 566 U.S. 639, 645 (2012) (citation omitted). Thus, this canon complements the canon

against implied repeal. Congress cannot be understood to have repealed the Wire Act and IGRA

when it passed Dodd-Frank. Moreover, the specific, express prohibition against sports gaming in

the Wire Act and IGRA governs over the broad, general definition of “swap.”

iii.

Noscitur a sociis .

Under the principle of noscitur a sociis – a word is known by the company it keeps – courts

must avoid ascribing to one word a meaning so broad that it is inconsistent with its accompanying

words, thus “giving unintended breadth to the Acts of Congress.” Yates v. United States , 574 U.S.

528, 543 (2015) (plurality) (citation and quotation marks omitted). When “several items in a list

share an attribute,” the principle favors “interpreting the other items as possessing that attribute as

well.” Beecham v. United States , 511 U.S. 368, 371 (1994). Here, surrounding sub-clause (ii) that

defines swaps as “associated with a potential financial, economic, or commercial consequence”

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