Case 1:25-cv-08846-AT Document 60-1 Filed 12/03/25 Page 10 of 31
a separate and distinct tribal government with the sovereign authority to conduct and regulate gaming activities on its Indian lands. The Amici Tribes all have a direct and immediate interest in maintaining their sovereign rights over gaming, including sports betting, on their Indian lands. Together, the Tribal Amici all have a shared, strong interest in this case because of its potential to have a significant impact on their or their member tribes’ rights regarding gaming on Indian lands, as well as Indian gaming and tribal governmental revenue as a whole. Such revenue is vital and provides funding for essential government services, tribal programs, and economic development needed to reach the goals of self-governance and self-sufficiency. ARGUMENT Indian tribes are sovereign nations with primary jurisdiction over their lands and activities occurring on their lands. In accordance with this principle, both the United States Supreme Court and Congress have recognized tribes’ inherent and exclusive sovereign right to conduct and regulate gaming on their Indian lands. California v. Cabazon Band of Mission Indians , 480 U.S. 202 (1987); 25 U.S.C. § 2701(5). Congress enacted the Indian Regulatory Gaming Act (“IGRA”) to provide a comprehensive federal regulatory framework for tribal gaming, including a mechanism for tribes and states to negotiate compacts governing Class III gaming, including sports betting. See 25 U.S.C. §§ 2702, 2703(8), 2710(d)(3). Based on this process, some states have negotiated compacts wherein tribes are the exclusive operators of certain types of gaming within the state. E.g. , Artichoke Joe’s California Grand Casino v. Norton , 353 F.3d 712, 718 (9th Cir. 2003). The revenue generated by tribal gaming supports thousands of jobs in hundreds of communities and provides critical funding to state and local
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