Case 3:25-cv-02016-VDO Document 56-1 Filed 01/16/26 Page 6 of 29
source of substantial revenue for tribes, but the lifeblood on which many tribes ha[ve] come to rely .” (internal quotations and citations omitted) (emphasis added)). B. Connecticut’s Cooperative Sports-Betting Regulatory Structure Working within IGRA’s comprehensive regulatory scheme, the Connecticut Tribes and the State of Connecticut have developed a model for gaming regulation that protects consumers, layers regulatory responsibility across tribal, state, and federal agencies, and provides significant revenues to governments serving tribal members and the people of Connecticut. In short, this model serves as a beacon for what is possible when tribes and states cooperate on gaming regulation under IGRA. The Mohegan Tribe first entered into an agreement with the State of Connecticut to regulate class III gaming in 1994. Tribal-State Compact Between the Mohegan Tribe and the State of Connecticut (Dec. 5, 1994), https://www.bia.gov/sites/default/files/dup/assets/as- ia/oig/pdf/508_compliant_1994.12.16_mohegan_tribe_of_indians_tribal_state_gaming_compact _0.pdf. Secretarial Procedures authorizing class III gaming for the Mashantucket Pequot Tribe were issued in 1991, followed by an agreement with the State concerning implementation of those Procedures in 1993. Memorandum of Understanding between the State of Connecticut and
Mashantucket Pequot Tribe (Jan. 13, 1993), https://portal.ct.gov/dcp/- /media/dcp/gaming/compacts-and-documents/mptn-mou-january-
1993.pdf?rev=5eda4c0b08554531866ff32aad3fe940&hash=079BB9A21D452B22F8F0DB7C45 E688C6. For more than 30 years, pursuant to and in reliance on these tribal-state agreements, the Connecticut Tribes have developed and operated world-renowned gaming operations, generating revenues that have provided critical government services that address a range of tribal citizen needs, including, but not limited to, education, public safety, housing, and healthcare.
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