Case 1:25-cv-12578-RGS Document 1 Filed 09/15/25 Page 25 of 28
its sports-related event contracts business in Massachusetts and would inflict upon Robinhood
the reputational harms noted above that would be associated with an enforcement action.
63.
Given the imminent threat that Massachusetts will attempt to enforce
preempted state law against Robinhood, Robinhood has no way to avoid irreparable harm absent
injunctive relief.
64.
There is an imminent likelihood that Defendants will violate the
Supremacy Clause. To prevent irreparable harm, Robinhood seeks declaratory and injunctive
relief restraining Defendants from enforcing Massachusetts law to the extent it purports to
regulate Robinhood’s offering of sports-related event contracts traded on a DCM.
COUNT I (Supremacy Clause – Preemption By Commodity Exchange Act)
65.
Robinhood restates, re-alleges, and incorporates by reference each of the
allegations set forth in the rest of this Complaint as if fully set forth herein.
66.
The Supremacy Clause, Article VI, Section 2, of the U.S. Constitution
provides:
This Constitution, and the Laws of the United States which shall be made in
Pursuance thereof; and all Treaties made, or which shall be made, under the
Authority of the United States, shall be the supreme Law of the Land; and the
Judges in every State shall be bound thereby, any Thing in the Constitution or
Laws of any State to the Contrary notwithstanding.
67.
The Supremacy Clause mandates that federal law preempt state law in any
field over which Congress has expressly or impliedly reserved exclusive authority to the federal
government and to the extent state law conflicts with federal law.
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