Cayuga Nation v. O'Dwyer

CourtDistrict Court, N.D. New York
DecidedJuly 30, 2025
Docket5:24-cv-00537
StatusUnknown

This text of Cayuga Nation v. O'Dwyer (Cayuga Nation v. O'Dwyer) 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. O'Dwyer, (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, and JERRY SKURNIK, in their official capacities as Commissioners of the New York State Gaming Commission,

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

Jennifer J. Hopkins Barclay Damon LLP 1742 N Street, NW Washington, D.C. 20036 For Defendants: Letitia James Attorney General of the State of New York Aimee Cowan Assistant Attorney General 300 South State Street, Suite 300 Syracuse, NY 13202 Hon. Brenda K. Sannes, Chief United States District Judge: MEMORANDUM-DECISION AND ORDER I. INTRODUCTION On April 18, 2024, Plaintiff Cayuga Nation (the “Nation”), a federally recognized Indian Nation, initiated 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. 1).1 The NYSGC and the Commissioners moved to dismiss the Nation’s complaint pursuant to Fed. R. Civ. P. 12(b)(1) and 12(b)(6), (Dkt. No. 37), and the Court heard oral argument on the motion on March 27, 2025. Following oral argument, the Court granted the motion to dismiss in part and denied it in part, dismissing the Nation’s claims as against NYSGC but otherwise denying the motion. (Dkt. No. 61). However, the Court granted the Commissioners permission to renew their motion to dismiss on the basis that the Nation lacked equity jurisdiction. (Id.). Currently before the Court is the Commissioners’ renewed motion to dismiss. (Dkt. No. 63).2 The motion is fully briefed. (Dkt. Nos. 63-1, 65, 76). For the

following reasons, the Court denies the Commissioners’ renewed motion to dismiss.

1 JackPocket, Inc. has subsequently been dismissed from this action. (See Dkt. No. 82). 2 After the renewed motion to dismiss was filed, the Nation filed the Second Amended Complaint (“SAC”), removing all claims and allegations against JackPocket. (See Dkt. No. 71, at 2 (“As part of the negotiated resolution between the Nation and Jackpocket, the Nation has agreed to withdraw all claims and allegations in the operative Complaint relating to Jackpocket, including the withdrawal of Counts III and IV.”)). The Commissioners consented to the filing of the SAC and requested that the Court consider the renewed motion to dismiss in light of the facts alleged therein. (Dkt. No. 78). Accordingly, all citations to the operative complaint are to the SAC, at Dkt. No. 80. Additionally, while the Court previously dismissed Defendant NYSGC from this case, the SAC continues to name the NYSGC as a Defendant. (See Dkt. No. 80). As the SAC contains no new allegations against NYSGC, the reasons for dismissal continue to apply, see Cayuga Nation v. N.Y. State Gaming Comm’n, 775 F. Supp. 3d 651, 663 (N.D.N.Y. 2025), and the Clerk of Court is directed to remove NYSGC from the caption. II. BACKGROUND The Court presumes the parties’ familiarity with its March 31, 2025 decision, which recites the statutory and factual background of the case. Cayuga Nation, 775 F. Supp. 3d at 655– 57. III. STANDARD OF REVIEW To survive a motion to dismiss under Rule 12(b)(6) for failure to state a claim, “a

complaint must provide ‘enough facts to state a claim to relief that is plausible on its face.’” Mayor & City Council of Balt. v. Citigroup, Inc., 709 F.3d 129, 135 (2d Cir. 2013) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). Mere “labels and conclusions” are insufficient; rather, a plaintiff must provide factual allegations sufficient “to raise a right to relief above the speculative level.” Twombly, 550 U.S. at 555 (citation omitted). The Court must “accept all factual allegations in the complaint as true and draw all reasonable inferences in favor of the plaintiff.” E.E.O.C. v. Port Auth., 768 F.3d 247, 253 (2d Cir. 2014) (citing ATSI Commc’ns, Inc. v. Shaar Fund, Ltd., 493 F.3d 87, 98 (2d Cir. 2007)). Additionally, “the tenet that a court must accept as true all of the allegations contained in a complaint is inapplicable to

legal conclusions.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). IV. DISCUSSION In support of their previous motion to dismiss, the State Defendants argued that the Nation could not pursue its claims because it lacked a private right of action under IGRA. (Dkt. No. 37-1, at 18–20). In response, the Nation appeared not to dispute the proposition that it lacked a private right of action in this case but instead argued that its “claims fall squarely within the federal courts’ long-established authority to enjoin ongoing violations of federal law.” (Dkt. No. 42, at 25; see generally id. at 22–25). Finding that “[a]t least one other district court ha[d] declined to dismiss a plaintiff tribe’s IGRA preemption claim on the basis that the court lacked equity jurisdiction,” and noting that “the parties ha[d] not meaningfully addressed whether the Court has equitable jurisdiction,” the Court explained that it could not determine that the Nation was unable to proceed with its claims at that time. Cayuga Nation, 775 F. Supp. 3d at 664–65 (citing Tohono O’odham Nation v. Ducey, 130 F. Supp. 3d 1301, 1316 (D. Ariz. 2015)).

However, the Court allowed the Commissioners to renew their motion such that the parties could adequately address the issue. See id. at 665–68. Now, in their renewed motion to dismiss, the Commissioners argue that “the Nation cannot rely on this Court’s equity jurisdiction as a substitute for a cause of action.” (Dkt. No. 63- 1, at 5). In response, the Nation contends for the first time that, while it may also proceed with its claims under the Court’s equity jurisdiction, it also has an express or implied right of action under IGRA. (Dkt. No. 65, at 9–16). The Nation had the opportunity to make these arguments in response to the State Defendants’ original motion. The Nation, however, did not contest the State Defendants’ argument, made in their first motion to dismiss, that IGRA did not confer a private right of

action. (See generally Dkt. No. 42). Instead, the Nation argued that it stated a claim for equitable relief, and that the State Defendants’ private-right-of-action argument “ignores the nature of relief the Nation seeks and the Court’s broad powers to provide redress for ongoing violations of federal law.” (Id. at 22). The Nation does not explain why, having forgone the opportunity to argue the existence of a private right of action, it may now do so, or why its initial position has changed. Nevertheless, the Court briefly addresses the Nation’s arguments on this subject before moving on to discuss the issue of equity jurisdiction. A. Private Right of Action The Nation argues that IGRA provides it with either an express or an implied right of action in this case. (Dkt. No. 65, at 9–16).

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Cayuga Nation v. O'Dwyer, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cayuga-nation-v-odwyer-nynd-2025.