Cayuga Nation v. New York State Gaming Commission

CourtDistrict Court, N.D. New York
DecidedMarch 31, 2025
Docket5:24-cv-00537
StatusUnknown

This text of Cayuga Nation v. New York State Gaming Commission (Cayuga Nation v. New York State Gaming Commission) is published on Counsel Stack Legal Research, covering District Court, N.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Cayuga Nation v. New York State Gaming Commission, (N.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF NEW YORK

CAYUGA NATION, a federally recognized Indian Nation,

Plaintiff, 5:24-cv-537 (BKS/TWD)

v.

NEW YORK STATE GAMING COMMISSION, BRIAN O’DWYER, in his official capacity as the Chair and Commissioner of the New York State Gaming Commission, JOHN A. CROTTY, SYLVIA B. HAMER, MARTIN J. MACK, PETER J. MOSCHETTI, JR., MARISSA SHORENSTEIN, JERRY SKURNIK, in their official capacities as Commissioners of the New York State Gaming Commission, and JACKPOCKET INC.,

Defendants.

Appearances: For Plaintiff: David G. Burch, Jr. Barclay Damon LLP 125 East Jefferson Street Syracuse, NY 13202

Kyra E. Ganswith Barclay Damon LLP 80 State Street Albany, NY 12207 For Defendants New York State Gaming Commission, Brian O’Dwyer, John A. Crotty, Sylvia B. Hamer, Martin J. Mack, Peter J. Moschetti, Jr., Marissa Shorenstein, and Jerry Skurnik: Letitia James Attorney General of the State of New York Aimee Cowan Assistant Attorney General 300 South State Street, Suite 300 Syracuse, NY 13202 For Defendant JackPocket, Inc.: Andrew Kim Goodwin Procter LLP 1900 N Street N.W. Washington, D.C. 20036

Chenxi Jiao Goodwin Procter LLP 620 Eighth Avenue New York, NY 10018

Christopher J.C. Herbert Goodwin Procter LLP 100 Northern Avenue Boston, MA 02210

Hon. Brenda K. Sannes, Chief United States District Judge: MEMORANDUM-DECISION AND ORDER I. INTRODUCTION Plaintiff Cayuga Nation (the “Nation”), a federally recognized Indian Nation, brings this action for declaratory and injunctive relief against the New York State Gaming Commission; Brian O’Dwyer, in his official capacity as Chair and Commissioner of the NYSGC; John A. Crotty, Sylvia B. Hamer, Martin J. Mack, Peter J. Moschetti, Jr., Marissa Shorenstein, and Jerry Skurnik, in their official capacities as Commissioners of the NYSGC; and JackPocket, Inc. (Dkt. No. 30). The Nation alleges that the Commission and the Commissioners (together, the “State Defendants”) are violating the Indian Gaming Regulatory Act (IGRA) by operating New York State lottery vending machines within the boundaries of the Cayuga Nation Reservation and by allowing JackPocket to operate within the Reservation pursuant to a Lottery Courier Service License. (Id.). Currently before the Court is the State Defendants’ motion to dismiss under Fed. R. Civ. P. 12(b)(1) and 12(b)(6). (Dkt. No. 37). The motion is fully briefed. (Dkt. Nos. 37-1, 42, 47). The Court heard oral argument on the motion on March 27, 2025. For the following reasons, the Court grants the State Defendants’ motion to dismiss in part and denies it in part. II. BACKGROUND A. IGRA IGRA was enacted following the Supreme Court’s 1987 decision in California v. Cabazon Band of Mission Indians, “which held that States lacked any regulatory authority over

gaming on Indian lands.” Michigan v. Bay Mills Indian Cmty., 572 U.S. 782, 794 (2014); see also California v. Cabazon Band of Mission Indians, 480 U.S. 202, 221–22 (1987). In its “Declaration of policy” IGRA names the following three purposes for the law’s enactment: (1) to provide a statutory basis for the operation of gaming by Indian tribes as a means of promoting tribal economic development, self-sufficiency, and strong tribal governments; (2) to provide a statutory basis for the regulation of gaming by an Indian tribe adequate to shield it from organized crime and other corrupting influences, to ensure that the Indian tribe is the primary beneficiary of the gaming operation, and to assure that gaming is conducted fairly and honestly by both the operator and players; and (3) to declare that the establishment of independent Federal regulatory authority for gaming on Indian lands, the establishment of Federal standards for gaming on Indian lands, and the establishment of a National Indian Gaming Commission are necessary to meet congressional concerns regarding gaming and to protect such gaming as a means of generating tribal revenue. 25 U.S.C. § 2702. “The Act divides gaming on Indian lands into three classes—I, II, and III—and provides a different regulatory scheme for each class.” Seminole Tribe of Florida v. Florida, 517 U.S. 44, 48 (1996). Class I gaming “means social games solely for prizes of minimal value or traditional forms of Indian gaming engaged in by individuals as a part of, or in connection with, tribal ceremonies or celebrations.” 25 U.S.C. § 2703(6). IGRA places “[c]lass I gaming on Indian lands” “within the exclusive jurisdiction of the Indian tribes.” Id. § 2710(a)(1). Class II gaming refers to bingo, “including (if played in the same location) pull-tabs, lotto, punch boards, tip jars, instant bingo, and other games similar to bingo,” as well as certain

card games, but does not include “any banking card games, including baccarat, chemin de fer, or blackjack (21),” or “electronic or electromechanical facsimiles of any game of chance or slot machines of any kind.” Id. § 2703(7). IGRA states that “[a]n Indian tribe may engage in, or license and regulate, class II gaming on Indian lands within such tribe’s jurisdiction, if” “such Indian gaming is located within a State that permits such gaming for any purpose by any person, organization or entity (and such gaming is not otherwise specifically prohibited on Indian lands by Federal law)” and “the governing body of the Indian tribe adopts an ordinance or resolution which is approved by the Chairman [of the National Indian Gaming Commission].” Id. § 2710(b)(1). Class II gaming is subject to additional regulations, including, for example, restrictions on revenue purposes, audit requirements, and background investigations on certain

personnel affiliated with a gaming enterprise. See id. § 2710(b). Class III gaming includes “all forms of gaming that are not class I gaming or class II gaming.” Id. § 2703(8). This category “includes casino games, slot machines, and horse racing.” Bay Mills Indian Cmty., 572 U.S. at 785 (citing 25 U.S.C. § 2703(8)). Class III gaming “is the most heavily regulated of the three classes” and: is lawful only where it is: (1) authorized by an ordinance or resolution that (a) is adopted by the governing body of the Indian tribe, (b) satisfies certain statutorily prescribed requirements, and (c) is approved by the National Indian Gaming Commission; (2) located in a State that permits such gaming for any purpose by any person, organization, or entity; and (3) “conducted in conformance with a Tribal–State compact entered into by the Indian tribe and the State under paragraph (3) that is in effect.” Seminole Tribe, 517 U.S. at 48–49 (citing 25 U.S.C. § 2710(d)(1)). A Tribal-State compact “typically prescribes rules for operating gaming, allocates law enforcement authority between the tribe and State, and provides remedies for breach of the agreement’s terms.” Bay Mills Indian Cmty., 572 U.S. at 785 (citing 25 U.S.C. §§ 2710(d)(3)(C)(ii), (v)).

B. Facts1 The Treaty of Canandaigua in 1794 established the Reservation, consisting of 64,015 acres, in what are today known as Seneca County, New York and Cayuga County, New York. (Dkt. No. 30, ¶¶ 29–30).

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Cayuga Nation v. New York State Gaming Commission, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cayuga-nation-v-new-york-state-gaming-commission-nynd-2025.