{ "source": "https://predictionmarketlaws.com", "license": "Free to reuse with a link to predictionmarketlaws.com", "checked": "2026-11-07", "documents": [ { "slug": "us-cftc-v-utah-complaint", "title": "United States and CFTC v. Utah: the federal complaint", "seo_title": "United States and CFTC v. Utah Complaint (Oct. 26, 2026): What the Federal Lawsuit Asks", "type": "complaint", "date": "2026-10-26", "issuer": "U.S. District Court for the District of Utah", "author": "Filed by the United States and the Commodity Futures Trading Commission. Signed by Timothy J. Borgerson of the Justice Department's Civil Division and Andrew J. Weisberg of the CFTC.", "case": "us-v-utah", "also_cases": [ "utah-v-kalshi" ], "states": [ "UT" ], "platforms": [ "Kalshi" ], "docket": "No. 2:26-cv-01055", "pages": 33, "outcome": "Pending", "files": [ { "label": "Complaint", "url": "https://www.cftc.gov/media/14796/OGC_UtahComplaint102626/download", "host": "Commodity Futures Trading Commission" } ], "summary": "The United States and the CFTC sued Utah and its Attorney General, Derek Brown, six days after Utah sued Kalshi and two Susquehanna trading firms in state court. The complaint argues that federal law preempts Utah's gambling, election-wagering and public-nuisance laws as applied to trading on CFTC-regulated exchanges, and asks the court to stop Utah from investigating or enforcing those laws against them.", "points": [ "Laws challenged. Utah's gambling provisions (Utah Code §§ 76-9-1401 to -1408), its ban on election wagers (§ 20A-1-606(2)) and its public-nuisance law (§ 78B-6a-102(2)), as applied to transactions on CFTC-regulated designated contract markets.", "The state case it targets. Brown v. Kalshi Inc., No. 260908356, filed Oct. 20, 2026 in Salt Lake County against five Kalshi entities, Susquehanna International Group LLP and Susquehanna Government Products LLLP.", "One claim, three theories. A single Supremacy Clause count arguing express, field and conflict preemption.", "Relief sought. A declaration that the Utah laws are preempted as applied to trading on designated contract markets, and preliminary and permanent injunctions against investigating or enforcing them against CFTC-regulated entities, their affiliates and partners." ], "why": "It is the latest of the suits the federal government has filed against states that moved against prediction markets, after Arizona, Connecticut, Illinois, Kentucky, Minnesota, New Mexico, New York and Wisconsin.", "cite": "Complaint, United States v. Utah, No. 2:26-cv-01055 (D. Utah Oct. 26, 2026).", "verified": "2026-11-07", "url": "https://predictionmarketlaws.com/documents/us-cftc-v-utah-complaint" }, { "slug": "sixth-circuit-kalshi-v-schuler-opinion", "title": "Sixth Circuit opinion in Kalshi's Ohio and Tennessee appeals", "seo_title": "Sixth Circuit Kalshi Ruling (Sept. 25, 2026): Sports Contracts Are Not Swaps", "type": "opinion", "date": "2026-09-25", "issuer": "U.S. Court of Appeals for the Sixth Circuit", "author": "Judge Julia Smith Gibbons wrote for a panel with Judges Eric L. Clay and Rachel S. Bloomekatz.", "case": "kalshi-v-schuler-6th-cir", "also_cases": [ "kalshi-v-orgel-6th-cir" ], "states": [ "OH", "TN" ], "platforms": [ "Kalshi" ], "docket": "Nos. 26-3196 and 26-5235", "outcome": "Ohio affirmed; Tennessee injunction vacated", "files": [ { "label": "Opinion", "url": "https://www.opn.ca6.uscourts.gov/opinions.pdf/26a0272p-06.pdf", "host": "U.S. Court of Appeals for the Sixth Circuit" }, { "label": "Full text", "url": "https://law.justia.com/cases/federal/appellate-courts/ca6/26-3196/26-3196-2026-09-25.html", "host": "Justia" } ], "summary": "Deciding Kalshi's Ohio and Tennessee appeals together, the Sixth Circuit held that Kalshi's sports event contracts are not swaps under the Commodity Exchange Act, which puts them outside the CFTC's exclusive jurisdiction. It upheld Ohio's win in the district court, vacated the injunction Kalshi had won in Tennessee, and sent both cases back. In the alternative, it held that even if the contracts were swaps, the Act would not preempt either state's gambling laws.", "points": [ "Kalshi can sue. The company may challenge state enforcement under Ex parte Young; the Act's remedy provisions do not displace that route.", "“Event” is broad. The court rejected the states' narrow reading and accepted that an event can include an outcome.", "The consequence must be inherent. A contract is a swap only if the event is inherently tied to a financial, economic or commercial consequence. Downstream or speculative effects, such as on sponsors or advertisers, are not enough.", "Not swaps, so not exclusive. Reading “involving swaps” to modify the whole list in the jurisdiction clause, the court held that contracts that are not swaps fall outside the CFTC's exclusive jurisdiction.", "Alternative holding. Even if the contracts were swaps, the Act would not expressly or impliedly preempt Ohio or Tennessee gambling law. Gambling is a field states have traditionally regulated, so the presumption against preemption applies." ], "quote": "we hold that Kalshi's sports-event contracts are not swaps under the CEA.", "why": "Two federal appeals courts have now rejected Kalshi's position and one has accepted it. Kalshi petitioned the Sixth Circuit for rehearing en banc on Oct. 9, 2026.", "cite": "KalshiEX LLC v. Schuler, Nos. 26-3196/5235, 2026 FED App. 0272P (6th Cir. Sept. 25, 2026).", "related": [ "third-circuit-kalshi-v-flaherty-opinion", "ninth-circuit-kalshi-v-assad-opinion" ], "verified": "2026-11-07", "url": "https://predictionmarketlaws.com/documents/sixth-circuit-kalshi-v-schuler-opinion" }, { "slug": "mo-attorney-general-kalshi-cease-and-desist-2026", "title": "Missouri Attorney General cease-and-desist letter to Kalshi", "seo_title": "Missouri's Cease-and-Desist Letter to Kalshi (Sept. 16, 2026): Get a License or Stop", "type": "cease_and_desist", "date": "2026-09-16", "issuer": "Missouri Attorney General's Office", "author": "Attorney General Catherine L. Hanaway, with Solicitor General Louis J. Capozzi III and Deputy Solicitor General Justin M. Ladendorf", "recipients": [ "KalshiEx LLC, through its registered agent" ], "states": [ "MO" ], "platforms": [ "Kalshi" ], "pages": 3, "outcome": "30 days to confirm", "files": [ { "label": "Letter", "url": "https://ago.mo.gov/wp-content/uploads/Kalshi-Cease-and-Desist-Letter.pdf", "host": "Missouri Attorney General's Office" } ], "summary": "Missouri's Attorney General gave Kalshi a choice: stop offering sports wagering in Missouri, or get a license from the Missouri Gaming Commission, pay the state's sports-wagering taxes and fees, and stop taking wagers from anyone under 21. The letter asks Kalshi to confirm within 30 days which it has done, and says the state will take legal action if it does not.", "points": [ "The choice. Cease and desist from sports wagering in Missouri, or obtain a Gaming Commission license, pay all associated taxes and fees, and stop serving Missouri residents under 21.", "The law cited. Article III, Section 39(g) of the Missouri Constitution, which legalized sports wagering, including its license fees and 10 percent tax on adjusted gross revenue, and the Gaming Commission's under-21 rules (11 CSR 45-20.360).", "The deadline. Confirmation of compliance or cessation within 30 days.", "The warning. The state will pursue enforcement and will not let Kalshi offer its platform in Missouri until the taxes and fees are paid." ], "why": "Kalshi sued the Attorney General and the Gaming Commission in federal court on Oct. 27, 2026 (E.D. Mo. No. 4:26-cv-01860). Novig's exchange and Crypto.com's exchange had sued Missouri on Oct. 16.", "cite": "Letter from Catherine L. Hanaway, Att'y Gen. of Mo., to KalshiEx LLC (Sept. 16, 2026).", "related_case": "kalshi-v-hanaway-edmo", "verified": "2026-11-07", "url": "https://predictionmarketlaws.com/documents/mo-attorney-general-kalshi-cease-and-desist-2026" }, { "slug": "scotus-crypto-com-v-nevada-cert-petition", "title": "Crypto.com's Supreme Court petition in North American Derivatives Exchange v. Nevada", "seo_title": "Crypto.com v. Nevada Supreme Court Petition (No. 26-344): The Question and Status", "type": "cert_petition", "date": "2026-09-11", "issuer": "Supreme Court of the United States", "author": "Filed by North American Derivatives Exchange, Inc., doing business as Crypto.com Derivatives North America. Counsel of record: Shay Dvoretzky, Skadden, Arps, Slate, Meagher & Flom LLP.", "case": "nadex-v-nevada-scotus", "states": [ "NV" ], "platforms": [ "Crypto.com" ], "docket": "No. 26-344", "pages": 36, "outcome": "Pending", "files": [ { "label": "Petition", "url": "https://www.supremecourt.gov/DocketPDF/26/26-344/423887/20260911105134903_CDNA%20v.%20Nevada%20-%20Cert%20Petition%20FILE.pdf", "host": "Supreme Court of the United States" }, { "label": "Docket", "url": "https://www.supremecourt.gov/docket/docketfiles/html/public/26-344.html", "host": "Supreme Court of the United States" } ], "question": "Whether the CEA preempts state regulation of sports-event contracts traded on a DCM.", "summary": "Crypto.com's U.S. derivatives exchange asks the Supreme Court to reverse the Ninth Circuit's decision for Nevada (No. 25-7187), arguing that the Commodity Exchange Act's plain text covers sports event contracts traded on a federally designated contract market and leaves no room for state regulation.", "points": [ "A split. The Third Circuit held that these contracts are swaps and that state regulation is preempted; the Ninth Circuit held the opposite.", "The Ninth Circuit was wrong. The petition points to the special rule that expressly mentions “gaming” contracts and to the CFTC's power to further define “swap,” and says the Ninth Circuit relied improperly on the major-questions doctrine.", "Stakes and vehicle. Conflicting rulings create the patchwork Congress meant to avoid, the questions are purely legal, and the CFTC filed as amicus below." ], "why": "The response deadline was extended to Nov. 16, 2026. On Nov. 6, 2026 Nevada asked for more time; the docket showed no ruling on that request when we checked.", "cite": "Petition for a Writ of Certiorari, N. Am. Derivatives Exch., Inc. v. Nevada, No. 26-344 (U.S. Sept. 11, 2026).", "related": [ "ninth-circuit-kalshi-v-assad-opinion", "scotus-flaherty-v-kalshi-cert-petition", "scotus-robinhood-v-dreitzer-cert-petition" ], "verified": "2026-11-07", "url": "https://predictionmarketlaws.com/documents/scotus-crypto-com-v-nevada-cert-petition" }, { "slug": "scotus-robinhood-v-dreitzer-cert-petition", "title": "Robinhood's Supreme Court petition in Robinhood v. Dreitzer", "seo_title": "Robinhood v. Nevada Supreme Court Petition (No. 26-338): The Question and Status", "type": "cert_petition", "date": "2026-09-10", "issuer": "Supreme Court of the United States", "author": "Filed by Robinhood Derivatives, LLC. Counsel of record: Lisa S. Blatt, Williams & Connolly LLP.", "case": "robinhood-v-dreitzer-scotus", "states": [ "NV" ], "platforms": [ "Robinhood" ], "docket": "No. 26-338", "outcome": "Pending", "files": [ { "label": "Petition", "url": "https://www.supremecourt.gov/DocketPDF/26/26-338/423750/20260910115039631_Robinhood%20Pet%20for%20Cert.pdf", "host": "Supreme Court of the United States" }, { "label": "Docket", "url": "https://www.supremecourt.gov/docket/docketfiles/html/public/26-338.html", "host": "Supreme Court of the United States" } ], "question": "Whether the Commodity Exchange Act preempts the application of state gaming laws to sports-related event contracts traded on federally regulated contract markets.", "summary": "Robinhood Derivatives, which offers event contracts to its customers as a futures commission merchant rather than running an exchange, asks the Supreme Court to review the Ninth Circuit's decision for Nevada (No. 25-7831) and to take the case alongside New Jersey's petition.", "points": [ "A split. The Ninth Circuit held that the Act does not preempt Nevada's gaming laws and expressly disagreed with the Third Circuit.", "Stakes. The petition cites more than 20 states that have brought or threatened enforcement, more than 30 suits by market participants, and appeals pending in six circuits and one state supreme court.", "A good vehicle. The case presents every preemption theory, including express preemption, which the Third Circuit did not decide." ], "why": "Nevada's response was due Nov. 13, 2026 after an extension granted Oct. 9, 2026.", "cite": "Petition for a Writ of Certiorari, Robinhood Derivatives, LLC v. Dreitzer, No. 26-338 (U.S. Sept. 10, 2026).", "related": [ "ninth-circuit-kalshi-v-assad-opinion", "scotus-flaherty-v-kalshi-cert-petition", "scotus-crypto-com-v-nevada-cert-petition" ], "verified": "2026-11-07", "url": "https://predictionmarketlaws.com/documents/scotus-robinhood-v-dreitzer-cert-petition" }, { "slug": "scotus-flaherty-v-kalshi-cert-petition", "title": "New Jersey's Supreme Court petition in Flaherty v. KalshiEX", "seo_title": "New Jersey v. Kalshi Supreme Court Petition (No. 26-299): The Question and Where It Stands", "type": "cert_petition", "date": "2026-09-02", "issuer": "Supreme Court of the United States", "author": "Filed by New Jersey. Counsel of record: Solicitor General Jeremy M. Feigenbaum.", "case": "flaherty-v-kalshiex-scotus", "states": [ "NJ" ], "platforms": [ "Kalshi" ], "docket": "No. 26-299", "pages": 33, "outcome": "Pending; Kalshi's response due Dec. 7, 2026", "files": [ { "label": "Petition", "url": "https://www.supremecourt.gov/DocketPDF/26/26-299/422751/20260902102245623_26-_PetitionForWritOfCertiorari.pdf", "host": "Supreme Court of the United States" }, { "label": "Docket", "url": "https://www.supremecourt.gov/docket/docketfiles/html/public/26-299.html", "host": "Supreme Court of the United States" } ], "question": "Whether the 2010 Dodd-Frank Wall Street Reform and Consumer Protection Act preempted States from regulating sports bets that occur within their jurisdictions if those bets are offered on markets registered with the Commodity Futures Trading Commission.", "summary": "New Jersey asks the Supreme Court to reverse the Third Circuit's decision for Kalshi. The petition argues that the 2010 Dodd-Frank Act did not take away a state's power to regulate sports bets placed within its borders just because the bets are offered on a CFTC-registered exchange, and that the federal appeals courts are now divided on the question.", "points": [ "A split. The Third Circuit's decision conflicts with the Ninth Circuit's ruling in Kalshi v. Assad, and the petition says most lower courts have ruled against the Third Circuit's view.", "Stakes. The question affects a multibillion-dollar industry, states' police power over gambling and about 20 states in litigation, and the petition warns that Kalshi's theory could reach tribal gaming and state-licensed sportsbooks.", "Not swaps. Sports outcomes are not “swaps” under the statute's text and context, and Dodd-Frank was a financial-crisis reform, not a move to put sports betting under federal control.", "No preemption even if they were. The CFTC's “exclusive jurisdiction” excludes other federal agencies, not states, and the savings clauses point the same way." ], "why": "Kalshi's response is due Dec. 7, 2026 after two extensions. Eleven amicus briefs were filed between Sept. 22 and Oct. 8, 2026, from groups including the National Football League, the American Gaming Association, 145 tribes, Ohio with 38 other states and D.C., and former CFTC Chairman Gary Gensler.", "cite": "Petition for a Writ of Certiorari, Flaherty v. KalshiEX, LLC, No. 26-299 (U.S. Sept. 2, 2026).", "related": [ "third-circuit-kalshi-v-flaherty-opinion", "scotus-robinhood-v-dreitzer-cert-petition", "scotus-crypto-com-v-nevada-cert-petition" ], "verified": "2026-11-07", "url": "https://predictionmarketlaws.com/documents/scotus-flaherty-v-kalshi-cert-petition" }, { "slug": "mi-v-kalshi-preliminary-injunction-order", "title": "Ingham County court order granting Michigan's injunction against Kalshi", "seo_title": "Michigan v. Kalshi Injunction (Sept. 1, 2026): The Order and Its $500,000-a-Day Penalty", "type": "injunction", "date": "2026-09-01", "issuer": "Ingham County Circuit Court, Michigan", "author": "Judge Rosemarie E. Aquilina", "case": "mi-v-kalshi-ingham", "states": [ "MI" ], "platforms": [ "Kalshi" ], "docket": "No. 26-1087-CZ", "pages": 5, "outcome": "Preliminary injunction granted", "files": [ { "label": "Order", "url": "https://www.michigan.gov/ag/-/media/Project/Websites/AG/releases/2026/September/Kalshi-Preliminary-Injunction-Order-Signed-Sep-1-2026.pdf?rev=9b1fd12fab2b4839a9910ba9f3cd77b7&hash=E3230B74592E2B13F3D9DF446965239B", "host": "Michigan Attorney General" }, { "label": "Attorney General's announcement", "url": "https://www.michigan.gov/ag/news/press-releases/2026/09/02/ag-nessel-secures-second-order-halting-unlawful-kalshi-sports-wagers-in-michigan", "host": "Michigan Attorney General" } ], "summary": "Judge Rosemarie E. Aquilina barred Kalshi from offering or facilitating internet sports betting contracts to anyone in Michigan until the case is decided. The order also bans marketing those contracts to Michigan residents, requires geofencing through a provider licensed by the Michigan Gaming Control Board, and makes Kalshi send the order to every futures commission merchant that offers its sports contracts.", "points": [ "No sports contracts. Kalshi may not offer, list, match, execute, clear, settle or otherwise facilitate internet sports betting contracts for anyone in Michigan or on any platform reachable from Michigan.", "No money or accounts. Kalshi may not take deposits or fees tied to those contracts from people in Michigan, or open, verify, fund or maintain accounts for trading them.", "No marketing. The ban covers websites, apps, email, push notifications, social media, influencers, affiliates and paid placements aimed at Michigan.", "No look-alikes. Kalshi may not launch functionally similar products, and the order lists single-game bets, parlays, teasers, moneylines, over-unders, in-game and proposition bets.", "Geofencing. Kalshi must use a third-party geolocation provider licensed by the Gaming Control Board that meets its 2024 technical standard, and owes $500,000 for each day the court finds it out of compliance.", "Notice to brokers. Within three business days Kalshi must give the order to every futures commission merchant offering its sports contracts." ], "why": "Michigan's Attorney General moved on Sept. 29, 2026 to hold Kalshi in civil contempt over sports promotions sent to Michigan users after the order. A show-cause hearing is set for Nov. 24, 2026.", "cite": "Nessel v. KalshiEX LLC, No. 26-1087-CZ (Mich. Cir. Ct. Ingham Cnty. Sept. 1, 2026) (order granting preliminary injunction).", "verified": "2026-11-07", "url": "https://predictionmarketlaws.com/documents/mi-v-kalshi-preliminary-injunction-order" }, { "slug": "cftc-perez-order", "title": "CFTC order over trading on advance copies of the President's speeches", "seo_title": "CFTC Order Against Gabriel Perez (Aug. 28, 2026): Trading Trump Mention Markets on Kalshi", "type": "cftc_order", "date": "2026-08-28", "issuer": "Commodity Futures Trading Commission", "case": "cftc-in-re-perez", "states": [], "platforms": [ "Kalshi" ], "docket": "CFTC Docket No. 26-06", "pages": 12, "outcome": "Settled; respondent neither admitted nor denied", "files": [ { "label": "Order", "url": "https://www.cftc.gov/media/14536/Enf_PerezConsentOrder082826/download", "host": "Commodity Futures Trading Commission" } ], "summary": "The CFTC found that Gabriel Perez, a federal employee who operated the teleprompter at President Trump's speaking engagements, used advance copies of the President's speeches to trade Kalshi contracts on which words the President would say. He accepted the order without admitting or denying the findings.", "points": [ "The conduct. From December 2025 to March 2026, Perez reviewed prepared speeches before delivery and bought Yes contracts on words in them and No contracts on words that were not, according to the order.", "The results. 43 contracts across 14 mention markets, profitable on 39, for a profit of $107,539.02.", "Violations found. Commodity Exchange Act Sections 4c(a)(3), 4c(a)(4)(C) and 6(c)(1), and CFTC Regulation 180.1(a)(1) and (a)(3). The order describes misappropriation of nonpublic government information.", "Sanctions. Disgorgement of $107,539.02, a $65,000 civil penalty that the order says was reduced about 40 percent for cooperation, a three-year trading ban and a cease-and-desist order." ], "why": "Unlike the Santos order, this one relies on the Commodity Exchange Act's ban on trading with nonpublic information taken from the federal government, Section 4c(a)(4)(C).", "cite": "In re Perez, CFTC No. 26-06 (Aug. 28, 2026).", "related": [ "cftc-santos-order" ], "verified": "2026-11-07", "url": "https://predictionmarketlaws.com/documents/cftc-perez-order" }, { "slug": "ninth-circuit-kalshi-v-assad-opinion", "title": "Ninth Circuit opinion in Kalshi v. Nevada", "seo_title": "Ninth Circuit Kalshi Ruling (Aug. 28, 2026): Why Nevada Won Kalshi v. Assad", "type": "opinion", "date": "2026-08-28", "issuer": "U.S. Court of Appeals for the Ninth Circuit", "author": "Judge Ryan D. Nelson wrote for a panel with Judges Bridget S. Bade and Kenneth K. Lee. Judge Lee also wrote a concurrence. There was no dissent.", "case": "kalshi-v-assad-9th-cir", "also_cases": [ "kalshi-v-hendrick-dnev" ], "states": [ "NV" ], "platforms": [ "Kalshi" ], "docket": "No. 25-7516", "outcome": "Affirmed in part, sent back in part", "files": [ { "label": "Opinion", "url": "https://cdn.ca9.uscourts.gov/datastore/opinions/2026/08/28/25-7516.pdf", "host": "U.S. Court of Appeals for the Ninth Circuit" }, { "label": "Full text", "url": "https://law.justia.com/cases/federal/appellate-courts/ca9/25-7516/25-7516-2026-08-28.html", "host": "Justia" } ], "summary": "The Ninth Circuit upheld the Nevada federal court's decision to dissolve the injunction that had protected Kalshi from Nevada's gaming regulators, at least for sports contracts. The panel held that Kalshi's sports event contracts are likely not swaps, so the Commodity Exchange Act's preemption of state law does not reach them. It sent Kalshi's election contracts back to the district court, which had not analyzed them separately.", "points": [ "The court can decide what a swap is. Nevada did not have to challenge a CFTC action to argue that Kalshi's contracts fall outside the definition.", "Sports contracts are likely not swaps. The panel read “event” and “associated with” narrowly, pointing to the gambling context, the lack of any limiting principle in Kalshi's reading, and major-questions concerns.", "Express preemption has limits. The Act does preempt state regulation of swaps traded on a designated contract market, but because these contracts are likely not swaps, that provision does not cover them.", "The CFTC's own rule. A CFTC regulation, 17 C.F.R. § 40.11, bars listing contracts that involve gaming, and the CFTC never used its discretionary review to approve these contracts.", "No field or conflict preemption. Both theories failed. Kalshi's claimed harms were speculative or self-inflicted, and the equities and public interest favored Nevada.", "Election contracts. Sent back so the district court can decide, in the first instance, whether they are swaps." ], "quote": "we affirm the district court's order dissolving the injunction as to sports event contracts.", "why": "The ruling created a split with the Third Circuit. Crypto.com's and Robinhood's Nevada appeals were decided for Nevada the same day, and both companies have petitioned the Supreme Court (Nos. 26-344 and 26-338).", "cite": "KalshiEX, LLC v. Assad, No. 25-7516 (9th Cir. Aug. 28, 2026).", "related": [ "scotus-robinhood-v-dreitzer-cert-petition", "scotus-crypto-com-v-nevada-cert-petition", "nv-gaming-control-board-kalshi-cease-and-desist-2025" ], "verified": "2026-11-07", "url": "https://predictionmarketlaws.com/documents/ninth-circuit-kalshi-v-assad-opinion" }, { "slug": "cftc-santos-order", "title": "CFTC order settling charges against George Santos over a Kalshi contract", "seo_title": "CFTC Order Against George Santos (July 31, 2026): The Kalshi State of the Union Trades", "type": "cftc_order", "date": "2026-07-31", "issuer": "Commodity Futures Trading Commission", "case": "cftc-in-re-santos", "states": [], "platforms": [ "Kalshi" ], "docket": "CFTC Docket No. 26-05", "outcome": "Settled; respondent neither admitted nor denied", "files": [ { "label": "Order", "url": "https://www.cftc.gov/media/14451/ENF_SantosOrder073126/download", "host": "Commodity Futures Trading Commission" } ], "summary": "The CFTC found that former Rep. George Santos traded Kalshi's contract on whether he would attend the Feb. 24, 2026 State of the Union while posting that he would attend, without disclosing that his flight and train had been cancelled or that he had exited his Yes position. He accepted the order without admitting or denying the findings.", "points": [ "The trades. Santos built a position of 30,874 Yes contracts on whether he would attend, then a position of 23,855 No contracts, according to the order.", "The statements. He posted on X that he would attend while his travel had been cancelled, and did not disclose the cancellations or that he had exited his Yes position.", "Violations found. Commodity Exchange Act Section 6(c)(1) and CFTC Regulation 180.1(a)(1) and (a)(3), the anti-fraud and anti-manipulation rules.", "Sanctions. A $17,500 civil penalty, disgorgement of $17,569.98, a three-year trading ban and a cease-and-desist order." ], "why": "The order applies the CFTC's general anti-fraud rule to trading on an event contract, the same rule it uses in other futures markets.", "cite": "In re Santos, CFTC No. 26-05 (July 31, 2026).", "related": [ "cftc-perez-order" ], "verified": "2026-11-07", "url": "https://predictionmarketlaws.com/documents/cftc-santos-order" }, { "slug": "sdny-kalshi-v-williams-order-injunction-pending-appeal", "title": "New York federal court order refusing Kalshi an injunction pending appeal", "seo_title": "Kalshi v. New York: Order Denying Kalshi's Emergency Injunction (July 27, 2026)", "type": "order", "date": "2026-07-27", "issuer": "U.S. District Court for the Southern District of New York", "author": "Judge Analisa Torres", "case": "kalshi-v-williams-sdny", "states": [ "NY" ], "platforms": [ "Kalshi" ], "docket": "No. 1:25-cv-08846", "entry": "ECF No. 113", "pages": 3, "outcome": "Emergency injunction denied", "files": [ { "label": "Order", "url": "https://www.ingame.com/wp-content/uploads/2026/07/gov.uscourts.nysd_.651836.113.0.pdf", "host": "InGame, copy of the court filing" } ], "summary": "Three weeks after denying Kalshi a preliminary injunction, Judge Analisa Torres also refused to stop New York from enforcing its gaming laws while Kalshi appeals. Kalshi had shown nothing new, she wrote: a proposed CFTC rule claiming preemption does not change the court's reading of the statute, and Kalshi's harms are mostly the ordinary costs of complying with state law.", "points": [ "A high bar. An earlier denial of a preliminary injunction carries significant weight, so only unusual circumstances justify changing course.", "Preemption. The court had already held that the Commodity Exchange Act does not preempt all state gambling laws as applied to swaps. A proposed CFTC rulemaking asserting express preemption does not change that, because the court interprets the statute itself.", "Harm. Kalshi's claimed harms are mainly monetary compliance costs. The risk to its federal registration as a contract market is speculative.", "Equities. The balance of hardships and the public interest favor New York, which identified significant harms from halting enforcement of its gaming rules." ], "quote": "Plaintiff's request for an emergency injunction pending appeal is DENIED.", "why": "Kalshi's appeal is pending at the Second Circuit (No. 26-1835). The case began with the New York State Gaming Commission's cease-and-desist letter of Oct. 24, 2025.", "cite": "KalshiEX LLC v. Williams, No. 1:25-cv-08846-AT, ECF No. 113 (S.D.N.Y. July 27, 2026).", "related": [ "ny-gaming-commission-kalshi-cease-and-desist-2025" ], "verified": "2026-11-07", "url": "https://predictionmarketlaws.com/documents/sdny-kalshi-v-williams-order-injunction-pending-appeal" }, { "slug": "wa-v-kalshi-preliminary-injunction-order", "title": "King County court order granting Washington's injunction against Kalshi", "seo_title": "Washington v. Kalshi Injunction (July 20, 2026): Judge Finds Kalshi Likely Broke State Gambling Law", "type": "injunction", "date": "2026-07-20", "issuer": "King County Superior Court, Washington", "author": "Judge John F. McHale", "case": "wa-v-kalshi", "states": [ "WA" ], "platforms": [ "Kalshi" ], "docket": "No. 26-2-10264-3 SEA", "pages": 14, "outcome": "Preliminary injunction granted; terms set later", "files": [ { "label": "Order", "url": "https://agportal-s3bucket.s3.us-west-2.amazonaws.com/Consumer%20Protection/Order%2020260720.pdf?VersionId=2q3iXAI8u1dsd1rayxjug3A4kh_KPxsX", "host": "Washington Attorney General's Office" }, { "label": "Attorney General's announcement", "url": "https://www.atg.wa.gov/news/news-releases/judge-finds-kalshi-s-online-gambling-likely-violates-state-law", "host": "Washington Attorney General's Office" } ], "summary": "Judge John F. McHale granted Washington's motion for a preliminary injunction, finding the state likely to prove that Kalshi's event contracts are illegal gambling under Washington law and that its “legal betting” advertising is likely deceptive. He rejected Kalshi's argument that federal commodities law displaces state gambling law, ordered Kalshi to preserve its records, and left the injunction's specific terms for further briefing. The order was signed July 17 and filed July 20, 2026.", "points": [ "Gambling Act. The state is likely to prove that Kalshi's event contracts violate Washington's laws on bookmaking, professional gambling and online gambling. Kalshi is not licensed by the Gambling Commission.", "Consumer Protection Act. Kalshi's “legal betting” advertising in Washington is likely an unfair or deceptive practice affecting the public interest.", "Recovery of gambling losses. The state is likely to succeed on its claim under Washington's law allowing recovery of money lost at gambling.", "No preemption. The Commodity Exchange Act's exclusive-jurisdiction clause consolidated federal futures regulation rather than shutting out the states, its savings clauses preserve state authority, and obeying Washington law would not stop Kalshi from meeting federal requirements.", "Federal rules don't override. The CFTC's impartial-access rule is a nondiscrimination rule, and the Act's reference to activity unlawful under state law means states decide what is unlawful within their borders.", "Harm. The court relied on evidence of problem gambling and its effects on families, noted that Kalshi ignored a 2025 Gambling Commission notice, and required no bond from the state." ], "quote": "The State of Washington's Motion for Preliminary Injunction is GRANTED.", "why": "The court set the injunction's terms on Aug. 12, 2026, requiring Kalshi to stop offering sports, election, political, entertainment and other listed contracts in Washington. Kalshi's appeal of the federal remand order is pending at the Ninth Circuit.", "cite": "State v. KalshiEx, LLC, No. 26-2-10264-3 SEA (Wash. Super. Ct. King Cnty. July 20, 2026) (order granting preliminary injunction).", "verified": "2026-11-07", "url": "https://predictionmarketlaws.com/documents/wa-v-kalshi-preliminary-injunction-order" }, { "slug": "third-circuit-kalshi-v-flaherty-opinion", "title": "Third Circuit opinion in Kalshi v. New Jersey", "seo_title": "Third Circuit Kalshi Ruling (April 6, 2026): What the Court Held in Kalshi v. New Jersey", "type": "opinion", "date": "2026-04-06", "issuer": "U.S. Court of Appeals for the Third Circuit", "author": "Judge David J. Porter wrote for the majority, joined by Chief Judge Michael A. Chagares. Judge Jane R. Roth dissented.", "case": "kalshi-v-flaherty-3d-cir", "states": [ "NJ" ], "platforms": [ "Kalshi" ], "docket": "No. 25-1922", "outcome": "Injunction affirmed, 2–1", "files": [ { "label": "Opinion", "url": "https://storage.courtlistener.com/recap/gov.uscourts.ca3.125099/gov.uscourts.ca3.125099.105.0.pdf", "host": "CourtListener, from the court's filing system" }, { "label": "Full text", "url": "https://law.justia.com/cases/federal/appellate-courts/ca3/25-1922/25-1922-2026-04-06.html", "host": "Justia" } ], "summary": "A divided Third Circuit panel upheld the order that bars New Jersey from enforcing its sports-wagering laws against Kalshi. The majority held that Kalshi's sports event contracts are swaps, that the Commodity Futures Trading Commission has exclusive jurisdiction over swaps traded on a federally designated contract market, and that federal law therefore preempts New Jersey's effort to regulate them. It was the first federal appeals court ruling on whether a state can regulate sports event contracts.", "points": [ "Swaps. Kalshi's sports contracts are “swaps” under the Commodity Exchange Act because their outcomes are associated with potential economic consequences. The court rejected New Jersey's narrower reading of the definition.", "Exclusive jurisdiction. Because the contracts trade on a CFTC-designated contract market, the CFTC's jurisdiction over them is exclusive.", "Field preemption. The preempted field is trading on designated contract markets, a form of futures trading, not gambling in general.", "Conflict preemption. Enforcing New Jersey law against these contracts would obstruct the Act's purpose of replacing a patchwork of state rules.", "Savings clauses. Neither of the Act's savings clauses preserves state enforcement against trading on a designated contract market.", "The other factors. Kalshi faced irreparable harm from threatened civil and criminal penalties and lost business, and the public interest favored enforcing the federal statute." ], "dissent": "Judge Roth would have applied a strong presumption against preemption because states have long regulated gambling. She read the savings clauses as leaving room for state law and concluded that Kalshi could comply with both federal and state rules.", "quote": "The Act preempts state laws that directly interfere with swaps traded on DCMs.", "why": "This is the decision Kalshi relies on most. The Ninth and Sixth Circuits later reached the opposite result, and New Jersey has asked the Supreme Court to review this one (No. 26-299).", "cite": "KalshiEX, LLC v. Flaherty, No. 25-1922 (3d Cir. Apr. 6, 2026).", "related": [ "d-nj-kalshi-v-flaherty-preliminary-injunction", "scotus-flaherty-v-kalshi-cert-petition" ], "verified": "2026-11-07", "url": "https://predictionmarketlaws.com/documents/third-circuit-kalshi-v-flaherty-opinion" }, { "slug": "il-gaming-board-polymarket-cease-and-desist-2026", "title": "Illinois Gaming Board cease-and-desist letter to Polymarket US", "seo_title": "Illinois Cease-and-Desist Letter to Polymarket US (Jan. 27, 2026)", "type": "cease_and_desist", "date": "2026-01-27", "issuer": "Illinois Gaming Board", "author": "Marcus D. Fruchter, administrator", "recipients": [ "QCX LLC, doing business as Polymarket US" ], "states": [ "IL" ], "platforms": [ "Polymarket" ], "pages": 2, "outcome": "No deadline set", "files": [ { "label": "Letter", "url": "https://igb.illinois.gov/content/dam/soi/en/web/igb/documents/sports/cease-and-desist-letters/20260127-cease-desist-letter-polymarket.pdf", "host": "Illinois Gaming Board" } ], "summary": "The Gaming Board sent Polymarket's U.S. exchange the demand it had sent Kalshi, Robinhood and Crypto.com in 2025: stop unlicensed sports wagering in Illinois or face possible civil or criminal penalties. This letter also cites an Illinois Supreme Court decision on what counts as gambling.", "points": [ "The demand. Polymarket US, and anyone affiliated with its operations, is “directed to cease and desist this illegal activity.”", "The law cited. The same statutes as the 2025 letters, plus J&J Ventures Gaming, LLC v. Wild, Inc., 2016 IL 119870.", "The warning. Possible civil or criminal penalties." ], "why": "Illinois was one of several states that wrote to Polymarket's U.S. exchange early in 2026; Tennessee's Sports Wagering Council had sent it a cease-and-desist letter on Jan. 9.", "cite": "Letter from Marcus D. Fruchter, Adm'r, Ill. Gaming Bd., to QCX LLC d/b/a Polymarket US (Jan. 27, 2026).", "related": [ "il-gaming-board-cease-and-desist-letters-2025" ], "verified": "2026-11-07", "url": "https://predictionmarketlaws.com/documents/il-gaming-board-polymarket-cease-and-desist-2026" }, { "slug": "ct-dcp-cease-and-desist-orders-2025", "title": "Connecticut cease-and-desist orders to Kalshi, Robinhood and Crypto.com", "seo_title": "Connecticut Cease-and-Desist Orders to Kalshi, Robinhood and Crypto.com (Dec. 2, 2025)", "type": "cease_and_desist", "date": "2025-12-02", "issuer": "Connecticut Department of Consumer Protection, Gaming Division", "author": "Kristofer Gilman, director of gaming", "recipients": [ "KalshiEX LLC (Case No. 2025-77)", "Robinhood Derivatives, LLC (Case No. 2025-336)", "Foris DAX Asia Pte. Ltd., doing business as Crypto.com (Case No. 2025-324)" ], "states": [ "CT" ], "platforms": [ "Kalshi", "Robinhood", "Crypto.com" ], "pages": 2, "outcome": "Stop immediately; let residents withdraw funds", "files": [ { "label": "Order to Kalshi", "url": "https://portal.ct.gov/dcp/-/media/dcp/news-releases-from-the-department-of-consumer-protection/2025/cease-and-desist---kalshiex-llc---case-no-2025-77.pdf?rev=bf04b7e8a4994a21a1e4960356036d4a&hash=E224C26FE80D14E896585AA7625361EC", "host": "Connecticut Department of Consumer Protection" }, { "label": "Order to Robinhood", "url": "https://portal.ct.gov/dcp/-/media/dcp/news-releases-from-the-department-of-consumer-protection/2025/cease-and-desist---robinhood---case-no-2025-336.pdf?rev=dc0a2114091549b6be9bccb2086a604f&hash=FA4AA18B951D838DAAAE02C0AE59CA52", "host": "Connecticut Department of Consumer Protection" }, { "label": "Order to Crypto.com", "url": "https://portal.ct.gov/dcp/-/media/dcp/news-releases-from-the-department-of-consumer-protection/2025/cease-and-desist---crypto-dot-com---case-no-2025-324.pdf?rev=cf23723702054466a7a3bb444397a0ba&hash=C58AD76C86AF7E635B14FCDC929BA434", "host": "Connecticut Department of Consumer Protection" }, { "label": "Department announcement, Dec. 3, 2025", "url": "https://portal.ct.gov/dcp/news-releases-from-the-department-of-consumer-protection/2025-news-releases/connecticut-consumer-protection-orders-cease-and-desist-conducting-unlicensed-online-gambling", "host": "Connecticut Department of Consumer Protection" } ], "summary": "Connecticut's gaming regulator ordered the three platforms to stop offering sports event contracts, or any other unlicensed online gambling, to Connecticut residents immediately, and to let residents withdraw the money the platforms held for them. The orders treat the contracts as unlicensed online sports wagering and professional gambling, and as void wagering contracts under state law.", "points": [ "The demand. Immediately stop advertising, offering, promoting or otherwise making available the contracts, or any other unlicensed online gambling, to Connecticut residents, and allow residents to withdraw their funds.", "The findings. Unlicensed gambling and professional gambling (Conn. Gen. Stat. §§ 53-278b and 53-278d), no online gaming operator's license (§ 12-857), and no applicable exception (§ 53-278g).", "Even if licensed. The orders say the contracts allow wagers by people under 21 and on Connecticut college teams (§§ 12-863(a)(1) and 12-850(30)), and that they are void under § 52-553.", "The warning. Civil penalties under the Connecticut Unfair Trade Practices Act and criminal penalties under the gambling statutes." ], "why": "Kalshi sued Connecticut officials the next day. Judge Vernon D. Oliver denied its motion for a preliminary injunction in August 2026, and Kalshi's appeal is at the Second Circuit. In September 2026 the department ordered nine more platforms to stop and issued about 30 subpoenas.", "cite": "Cease and Desist Letter to KalshiEX LLC, Conn. Dep't of Consumer Prot. Case No. 2025-77 (Dec. 2, 2025).", "related_case": "kalshi-v-cafferelli-dconn", "verified": "2026-11-07", "url": "https://predictionmarketlaws.com/documents/ct-dcp-cease-and-desist-orders-2025" }, { "slug": "ny-gaming-commission-kalshi-cease-and-desist-2025", "title": "New York State Gaming Commission cease-and-desist letter to Kalshi", "seo_title": "New York's Cease-and-Desist Letter to Kalshi (Oct. 24, 2025): What It Says", "type": "cease_and_desist", "date": "2025-10-24", "issuer": "New York State Gaming Commission", "author": "Robert Williams, executive director", "recipients": [ "Xavier Sottile, head of markets, KalshiEX LLC" ], "states": [ "NY" ], "platforms": [ "Kalshi" ], "outcome": "Stop immediately", "files": [ { "label": "Letter", "url": "https://gaming.ny.gov/system/files/documents/2026/03/2025-10-24-williams-to-kalshi.pdf", "host": "New York State Gaming Commission" } ], "summary": "The Commission ordered Kalshi to stop operating what it called an unlicensed mobile sports wagering platform in New York, including the event contracts listed in the letter, and to confirm that it had stopped. It cited New York's racing and wagering law and the Penal Law's definition of gambling, and reserved the right to penalize past, current and future activity.", "points": [ "The demand. “Cease and desist immediately” from operating, advertising, promoting or otherwise making available an unlicensed mobile sports wagering platform in New York, and confirm compliance.", "The law cited. Racing, Pari-Mutuel Wagering and Breeding Law §§ 104(1), 104(9), 104(24), 1367(1), 1367(2)(a), 1367-a(2)(a) and 1367-a(4)(b), and Penal Law § 225.00(2).", "The warning. Civil penalties and fines under § 104(9), and further investigation of Kalshi's sports wagering in New York." ], "why": "Kalshi sued the Commission two days later. Judge Analisa Torres denied Kalshi a preliminary injunction on July 7, 2026 and an injunction pending appeal on July 27, 2026; the appeal is at the Second Circuit.", "cite": "Letter from Robert Williams, Exec. Dir., N.Y. State Gaming Comm'n, to Xavier Sottile, KalshiEX LLC (Oct. 24, 2025).", "related": [ "sdny-kalshi-v-williams-order-injunction-pending-appeal" ], "related_case": "kalshi-v-williams-sdny", "verified": "2026-11-07", "url": "https://predictionmarketlaws.com/documents/ny-gaming-commission-kalshi-cease-and-desist-2025" }, { "slug": "d-md-kalshi-v-martin-opinion", "title": "Maryland federal court opinion denying Kalshi an injunction", "seo_title": "Kalshi v. Maryland Ruling (Aug. 1, 2025): Why Judge Abelson Denied Kalshi's Injunction", "type": "opinion", "date": "2025-08-01", "issuer": "U.S. District Court for the District of Maryland", "author": "Judge Adam B. Abelson", "case": "kalshi-v-martin-dmd", "states": [ "MD" ], "platforms": [ "Kalshi" ], "docket": "No. 1:25-cv-01283", "entry": "ECF No. 70", "pages": 30, "outcome": "Preliminary injunction denied", "files": [ { "label": "Memorandum opinion", "url": "https://www.govinfo.gov/content/pkg/USCOURTS-mdd-1_25-cv-01283/pdf/USCOURTS-mdd-1_25-cv-01283-0.pdf", "host": "GovInfo, U.S. Government Publishing Office" } ], "summary": "Judge Adam B. Abelson refused to block Maryland from enforcing its gaming laws against Kalshi's sports event contracts. He assumed, without deciding, that the contracts are swaps, and held that Kalshi still had not shown that the Commodity Exchange Act preempts state gambling law. It was the first federal court ruling against Kalshi on preemption.", "points": [ "Swaps assumed. The court assumed the contracts are swaps and decided the case on preemption alone.", "No field preemption. Regulating gambling is a core state power, so a presumption against preemption applies, and Kalshi did not show that Congress clearly meant to strip states of that power over sports wagers on a designated contract market.", "Exclusive jurisdiction read narrowly. The exclusive-jurisdiction clause mainly divides authority among federal agencies such as the CFTC and the SEC. The savings clause is ambiguous and, on balance, cuts against field preemption.", "The statute's structure. The special rule refers to activity unlawful under state law, and the Act's express preemption clause covers gaming only for certain transactions. Both suggest Congress did not mean to displace state gaming law broadly.", "No conflict preemption. Kalshi could get a Maryland sports-wagering license and still meet its federal obligations.", "Other factors not reached. Because Kalshi was unlikely to succeed, the court did not decide irreparable harm, the balance of equities or the public interest." ], "why": "Kalshi appealed to the Fourth Circuit (No. 25-1892), and Maryland agreed in writing not to enforce against Kalshi while the appeal is pending. The appeal was argued May 7, 2026 and is undecided.", "cite": "KalshiEX LLC v. Martin, No. 25-cv-1283-ABA, ECF No. 70 (D. Md. Aug. 1, 2025).", "verified": "2026-11-07", "url": "https://predictionmarketlaws.com/documents/d-md-kalshi-v-martin-opinion" }, { "slug": "d-nj-kalshi-v-flaherty-preliminary-injunction", "title": "New Jersey federal court opinion granting Kalshi an injunction", "seo_title": "Kalshi v. New Jersey Injunction (April 28, 2025): What Judge Kiel Decided", "type": "opinion", "date": "2025-04-28", "issuer": "U.S. District Court for the District of New Jersey", "author": "Judge Edward S. Kiel", "case": "kalshi-v-flaherty-dnj", "states": [ "NJ" ], "platforms": [ "Kalshi" ], "docket": "No. 1:25-cv-02152", "entry": "ECF No. 21", "pages": 16, "outcome": "Preliminary injunction granted", "files": [ { "label": "Opinion", "url": "https://www.govinfo.gov/content/pkg/USCOURTS-njd-1_25-cv-02152/pdf/USCOURTS-njd-1_25-cv-02152-0.pdf", "host": "GovInfo, U.S. Government Publishing Office" } ], "summary": "Judge Edward S. Kiel barred New Jersey's Division of Gaming Enforcement from enforcing the state's sports-wagering laws against Kalshi. He found that Kalshi's sports event contracts likely fall within the CFTC's exclusive jurisdiction because Kalshi is a federally designated contract market, and that Kalshi had a reasonable chance of winning on field preemption. He set a $100,000 bond.", "points": [ "Exclusive federal jurisdiction. The Commodity Exchange Act gives the CFTC authority over swaps and similar contracts traded on designated contract markets, and the savings clauses do not restore state power over them.", "Sports contracts are covered. The court rejected the argument that sporting events lack a financial or economic consequence.", "Field preemption is enough. Kalshi showed a reasonable chance of success on field preemption, so the court did not reach conflict preemption.", "Gaming concerns go to the CFTC. The Act's special rule for event contracts routes public-interest concerns about gaming to CFTC review, not to state gaming enforcement.", "Irreparable harm. Kalshi showed likely harm to its reputation and goodwill. The court gave weight to a partner's decision not to list Kalshi contracts in New Jersey after receiving a similar cease-and-desist letter.", "Bond. The court set bond at $100,000, matching the maximum fine under New Jersey's sports-wagering law." ], "quote": "Kalshi's sports-related event contracts fall within the CFTC's exclusive jurisdiction.", "why": "The Third Circuit affirmed this injunction on April 6, 2026, and New Jersey's Supreme Court petition (No. 26-299) asks the justices to reverse it.", "cite": "KalshiEX LLC v. Flaherty, No. 25-cv-02152-ESK-MJS, ECF No. 21 (D.N.J. Apr. 28, 2025).", "related": [ "third-circuit-kalshi-v-flaherty-opinion" ], "verified": "2026-11-07", "url": "https://predictionmarketlaws.com/documents/d-nj-kalshi-v-flaherty-preliminary-injunction" }, { "slug": "il-gaming-board-cease-and-desist-letters-2025", "title": "Illinois Gaming Board cease-and-desist letters to Kalshi, Robinhood and Crypto.com", "seo_title": "Illinois Cease-and-Desist Letters to Kalshi, Robinhood and Crypto.com (April 1, 2025)", "type": "cease_and_desist", "date": "2025-04-01", "issuer": "Illinois Gaming Board", "author": "Marcus D. Fruchter, administrator", "recipients": [ "KalshiEX LLC (Tarek Mansour and Eliezer Mishory)", "Robinhood (Vlad Tenev)", "Crypto.com (Kris Marszalek and Eric Anziani)" ], "states": [ "IL" ], "platforms": [ "Kalshi", "Robinhood", "Crypto.com" ], "outcome": "No deadline set", "files": [ { "label": "Letter to Kalshi", "url": "https://igb.illinois.gov/content/dam/soi/en/web/igb/documents/sports/cease-and-desist-letters/20250401-cease-desist-letter-kalshi.pdf", "host": "Illinois Gaming Board" }, { "label": "Letter to Robinhood", "url": "https://igb.illinois.gov/content/dam/soi/en/web/igb/documents/sports/cease-and-desist-letters/20250401-cease-desist-letter-robinhood.pdf", "host": "Illinois Gaming Board" }, { "label": "Letter to Crypto.com", "url": "https://igb.illinois.gov/content/dam/soi/en/web/igb/documents/sports/cease-and-desist-letters/20250401-cease-desist-letter-crypto-com.pdf", "host": "Illinois Gaming Board" }, { "label": "The Board's list of cease-and-desist letters", "url": "https://igb.illinois.gov/sports-wagering/cease-and-desist-letters.html", "host": "Illinois Gaming Board" } ], "summary": "On the same day the Illinois Gaming Board sent nearly identical letters to Kalshi, Robinhood and Crypto.com, directing each to stop what the Board called unlicensed sports wagering in Illinois. Each letter cites the Illinois Sports Wagering Act and the gambling section of the state criminal code and warns of civil or criminal penalties. None sets a deadline.", "points": [ "The demand. Each company, and anyone affiliated with its operations, is “directed to cease and desist this illegal activity.”", "The law cited. The Sports Wagering Act (230 ILCS 45, including 45/25-10 and 45/25-20(a)), the Criminal Code's gambling offense (720 ILCS 5/28-1(a)), 230 ILCS 10/18(a)(1), 730 ILCS 5/5-4.5-55 and 11 Ill. Adm. Code 1900.1210(a).", "The warning. Failure to comply may bring civil or criminal penalties." ], "why": "Kalshi and Coinbase later sued Illinois, and the United States and the CFTC sued the state in April 2026. On Oct. 30, 2026 a federal judge entered a preliminary injunction barring enforcement of specified Illinois gambling laws against swaps, including sports event contracts, on CFTC-regulated exchanges. Illinois has appealed.", "cite": "Letter from Marcus D. Fruchter, Adm'r, Ill. Gaming Bd., to KalshiEX LLC (Apr. 1, 2025).", "related": [ "il-gaming-board-polymarket-cease-and-desist-2026" ], "related_case": "kalshi-v-raoul-ndill", "verified": "2026-11-07", "url": "https://predictionmarketlaws.com/documents/il-gaming-board-cease-and-desist-letters-2025" }, { "slug": "mt-gambling-control-kalshi-cease-and-desist-2025", "title": "Montana Gambling Control Division cease-and-desist letter to Kalshi", "seo_title": "Montana's Cease-and-Desist Letter to Kalshi (March 26, 2025)", "type": "cease_and_desist", "date": "2025-03-26", "issuer": "Montana Department of Justice, Gambling Control Division", "author": "Jeremy S. Craft, chief legal counsel", "recipients": [ "KalshiEX, LLC" ], "states": [ "MT" ], "platforms": [ "Kalshi" ], "outcome": "No deadline set", "files": [ { "label": "Letter", "url": "https://ewscripps.brightspotcdn.com/be/9d/89ca709a491b991f15de4c31218b/2025-03-26-cease-desist.pdf", "host": "Scripps News, copy of the letter" } ], "summary": "Montana's gambling regulator told Kalshi to stop what it called illegal gambling in the state, citing Montana's gambling and sports-wagering laws, and warned that refusal would lead to legal action and possible referral for prosecution. The letter asked for voluntary compliance and set no deadline.", "points": [ "The demand. Cease and desist illegal gambling activity within Montana.", "The law cited. MCA §§ 23-5-112, 23-5-113, 23-5-136, 23-5-152, 23-5-154, 23-5-157 and 23-7-103, and Montana administrative rules 23.16.3001 and 23.16.3002.", "The warning. Refusal would result in legal action against KalshiEX, and the Division may refer illegal gambling for prosecution." ], "why": "According to Kalshi's later complaint, the Division agreed in writing in April 2025 not to enforce while Kalshi's Nevada injunction stood. After that injunction was dissolved, the Division sent a second letter on April 6, 2026. Kalshi sued six days later, and the case was dismissed by stipulation on Sept. 21, 2026.", "cite": "Letter from Jeremy S. Craft, Chief Legal Counsel, Mont. Gambling Control Div., to KalshiEX, LLC (Mar. 26, 2025).", "related_case": "kalshi-v-knudsen-dmont", "verified": "2026-11-07", "url": "https://predictionmarketlaws.com/documents/mt-gambling-control-kalshi-cease-and-desist-2025" }, { "slug": "nv-gaming-control-board-kalshi-cease-and-desist-2025", "title": "Nevada Gaming Control Board cease-and-desist letter to Kalshi", "seo_title": "Nevada's Cease-and-Desist Letter to Kalshi (March 4, 2025): What It Demanded", "type": "cease_and_desist", "date": "2025-03-04", "issuer": "Nevada Gaming Control Board", "author": "Signed by Chairman Kirk Hendrick, according to the Board's announcement", "recipients": [ "Tarek Mansour, chief executive, KalshiEX LLC", "Eliezer Mishory, chief regulatory officer and general counsel" ], "states": [ "NV" ], "platforms": [ "Kalshi" ], "outcome": "Deadline March 14, 2025", "files": [ { "label": "Letter, as filed in Kalshi v. CFTC (D.C. Cir. No. 24-5205)", "url": "https://business.cch.com/srd/20250306_Kalshi-v-CFTC_letter_Nevada-GCB.pdf", "host": "Wolters Kluwer, copy of the court filing" }, { "label": "Board announcement", "url": "https://www.gaming.nv.gov/uploadedFiles/gamingnvgov/content/about/press-release/NGCB%20-%20News%20Release%20-%20KalshiEX%20Cease%20and%20Desist%20Order%20(3-4-2025).pdf", "host": "Nevada Gaming Control Board" } ], "summary": "The Board ordered Kalshi to stop offering any event-based contracts in Nevada and to confirm in writing by 5 p.m. on March 14, 2025 that it had stopped. Sports and election contracts are unlawful in Nevada unless approved as licensed gaming, the Board said, and even licensed sports pools may not take wagers on elections.", "points": [ "The demand. Cease and desist immediately from offering any event-based contracts in Nevada, and confirm in writing that all prohibited activity has stopped.", "The deadline. 5 p.m. on March 14, 2025.", "The law cited. NRS 463.0193 and 463.01962 (sports pool and wager definitions), 463.160 (licensing), 463.245, 463.360(3), 465.086, 465.092 and 293.830 (election wagering), plus Gaming Commission regulations.", "The warning. Operating without a license is a category B felony under NRS 463.360(3), and any violation after receipt of the letter would be treated as willful." ], "why": "Kalshi sued the Board's members on March 28, 2025 and won a preliminary injunction that the court dissolved in November 2025. The Ninth Circuit upheld the dissolution on Aug. 28, 2026.", "cite": "Letter from Nev. Gaming Control Bd. to Tarek Mansour & Eliezer Mishory, KalshiEX LLC (Mar. 4, 2025).", "related": [ "ninth-circuit-kalshi-v-assad-opinion" ], "related_case": "kalshi-v-hendrick-dnev", "verified": "2026-11-07", "url": "https://predictionmarketlaws.com/documents/nv-gaming-control-board-kalshi-cease-and-desist-2025" }, { "slug": "ddc-kalshi-v-cftc-order", "title": "D.C. federal court order striking down the CFTC's ban on Kalshi's election contracts", "seo_title": "Kalshi v. CFTC Order (Sept. 6, 2024): The Ruling That Let Kalshi List Election Contracts", "type": "order", "date": "2024-09-06", "issuer": "U.S. District Court for the District of Columbia", "author": "Judge Jia M. Cobb", "case": "kalshi-v-cftc-ddc", "states": [], "platforms": [ "Kalshi" ], "docket": "No. 1:23-cv-03257", "entry": "ECF No. 47", "pages": 1, "outcome": "Summary judgment for Kalshi; CFTC order vacated", "files": [ { "label": "Order", "url": "https://storage.courtlistener.com/recap/gov.uscourts.dcd.261465/gov.uscourts.dcd.261465.47.0.pdf", "host": "CourtListener, from the court's filing system" } ], "summary": "In a one-page order, Judge Jia M. Cobb granted Kalshi summary judgment, denied the CFTC's cross-motion and vacated the CFTC's Sept. 22, 2023 order that had barred Kalshi from listing contracts on which party would control Congress. She made it a final, appealable order. Her memorandum opinion explaining the ruling followed on Sept. 12, 2024.", "points": [ "Kalshi's motion for summary judgment (ECF No. 17) granted.", "The CFTC's cross-motion for summary judgment (ECF No. 30) denied.", "The CFTC's Sept. 22, 2023 order prohibiting Kalshi's congressional control contracts vacated.", "Designated a final appealable order, which allowed the CFTC to appeal to the D.C. Circuit." ], "why": "The ruling cleared the way for federally regulated election contracts before the 2024 election. The CFTC appealed and then dropped the appeal in May 2025, so the decision stands. Courts in the later state cases often cite it.", "cite": "KalshiEX LLC v. CFTC, No. 23-cv-3257 (JMC), ECF No. 47 (D.D.C. Sept. 6, 2024).", "verified": "2026-11-07", "url": "https://predictionmarketlaws.com/documents/ddc-kalshi-v-cftc-order" } ] }