Cox v. The New York Racing Association

CourtDistrict Court, S.D. Ohio
DecidedSeptember 2, 2025
Docket1:25-cv-00529
StatusUnknown

This text of Cox v. The New York Racing Association (Cox v. The New York Racing Association) is published on Counsel Stack Legal Research, covering District Court, S.D. Ohio primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Cox v. The New York Racing Association, (S.D. Ohio 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO WESTERN DIVISION AT CINCINNATI

WELBY THOMAS COX, JR.,

Plaintiff, Case No. 1:25-cv-529

v. Judge Michael R. Barrett

NEW YORK RACING ASS’N, et al.,

Defendants. ORDER

This matter is before the Court on the Report and Recommendation (“R&R”) filed by the Magistrate Judge on August 18, 2025. (Doc. 7). Proper notice was given to Plaintiff (who proceeds pro se) under Fed. R. Civ. P. 72(b), including notice that he may forfeit rights on appeal if he failed to file objections to the R&R in a timely manner.1 United States v. Walters, 638 F.2d 947 (6th Cir. 1981); see Berkshire v. Dahl, 928 F.3d 520, 530 (6th Cir. 2019). Plaintiff has filed timely objections. (Doc. 8-1). Standard. When objections to a magistrate judge’s report and recommendation are received on a dispositive matter, the assigned district judge “must determine de novo any part of the magistrate judge’s disposition that has been properly objected to.” Fed. R. Civ. P. 72(b)(3) (emphasis added). After review, the district judge “may accept, reject, or modify the recommended disposition; receive further evidence; or return the matter to the magistrate judge with instructions.” Id.; see also 28 U.S.C. § 636(b)(1). General objections are insufficient to preserve an issue for review. “A general objection to the entirety of the magistrate[ judge]’s report has the same effects as would

1 (Doc. 7 PAGEID 42). a failure to object. The district court’s attention is not focused on any specific issues for review, thereby making the initial reference to the magistrate [judge] useless.” Howard v. Sec'y of Health & Human Servs., 932 F.2d 505, 509 (6th Cir. 1991); see Aldrich v. Bock, 327 F. Supp. 2d 743, 747 (E.D. Mich. 2004) (“An ‘objection’ that does nothing more than state a disagreement with a magistrate[ judge]’s suggested resolution, or simply summarizes what has been presented before, is not an ‘objection’ as that term is used in

this context.”); Renchen v. Comm’r of Soc. Sec., No. 1:13-cv-752, 2015 WL 1097349, at *6 (S.D. Ohio Mar. 11, 2015) (plaintiff’s objection “is an almost verbatim recitation of the argument presented to and considered by the Magistrate Judge” and therefore need not be reconsidered) (citing Howard, 932 F.2d at 508–09). Plaintiff’s Verified Complaint. Plaintiff sues The New York Racing Association, United Tote Company, and unknown (“John Doe”) computer-assisted wagering (“CAW”) entities, alleging, in overall terms, that their participation “has fundamentally altered the fairness of pari-mutuel wagering systems[2] across state lines, including Ohio.” (Doc. 6 PAGEID 31). This case, he asserts, “implicates federal issues regarding consumer deception, wire transmissions in interstate wagering pools, and the denial of due process to retail bettors.” (Id. ¶ 2). Plaintiff invokes federal question subject-matter jurisdiction under 28 U.S.C. § 1331. (Id. ¶ 1).3 His claims are labelled “Unfair and Deceptive Trade Practices” (Count I) and “Denial of Equal Access and Due Process”) (Count II).

2 As the Sixth Circuit recently explained, “[p]ari-mutuel wagers differ from ordinary wagers. Rather than betting against the racetrack, each bettor bets against all other bettors. Bettors stand to win a share of the total pool of money wagered. The payout for each winning wager is determined by dividing the pools based on a set formula. After the Kentucky Horse Racing Commission's appointed stewards declare the race ‘official,’ bettors ‘exchange their winning ticket for the money due to them.’ As compensation for administering the wagers, the racetrack receives the ‘takeout,’ a fixed percentage of the money wagered.” Mattera v. Baffert, 100 F.4th 734, 736 (6th Cir. 2024) (citations to the record omitted).

3 Plaintiff also invokes 28 U.S.C. § 1337, which provides (in part): “The district courts shall have original jurisdiction of any civil action or proceeding arising under any Act of Congress regulating commerce or protecting trade and commerce against restraints and monopolies[.] . . .” (Id. ¶¶ 14–16, ¶¶ 17–19). Summary of the R&R. As to Count I, the Magistrate Judge observes that Plaintiff cites to no federal or state statute in support. (Doc. 7 PAGEID 39–40). The federal statute that outlaws unfair or deceptive acts or practices “in or affecting commerce” is § 5 of the Federal Trade Commission Act (“FTCA”), codified at 15 U.S.C. § 45. (Id. PAGEID 40). However, “courts have uniformly held that a private right of action does not exist under

§ 5 of the FTCA.” (Id. (quoting Morales v. Walker Motors Sales, Inc., 162 F. Supp. 2d 786, 790 (S.D. Ohio 2000))). A private right of action does exist under Ohio’s Deceptive Trade Practices Act4, but this Court lacks diversity (of citizenship) subject-matter jurisdiction because the complaint fails to plead the $75,000 amount-in-controversy requirement. (Id. (quoting 28 U.S.C. § 1332(a)). In fact, Plaintiff’s Prayer for Relief only seeks an award of nominal damages in the amount of $1.00. (Id.). As to Count II, the Magistrate Judge matter-of-factly states that she “is unable to discern a legal basis” for Plaintiff’s “claim of the denial of ‘equal access’ under the laws or constitution of the United States.” (Doc. 7 PAGEID 39). Concerning his due process claim, the Magistrate Judge notes that none of the defendants are state actors as required under 42 U.S.C. § 1983. (Doc. 7 PAGEID 37–38). But even if Plaintiff sufficiently alleged state action for § 1983 purposes, he failed to plead, as a predicate, “that state remedies for redressing the wrong are inadequate.” (Id. PAGEID 38 (quoting Victory v. Walton, 721 F.2d 1062, 1066 (6th Cir. 1983))). As the Magistrate Judge explains, “[a] plaintiff ‘may not seek relief under [42 U.S.C. §] 1983 without first pleading and proving the inadequacy of state or administrative processes and remedies to redress [his] due

process violations.’” (Id. (quoting Jefferson v. Jefferson Cty. Pub. Sch. Sys., 360 F.3d

4 See Ohio Rev. Code §§ 4165.01 et seq. 583, 588 (6th Cir. 2004))). Plaintiff’s Objections. Plaintiff first contends, without citation to any authority, that sua sponte dismissal “is a ‘drastic remedy’ and should be applied cautiously[.]” (Doc. 8-1 PAGEID 53). Not so. The federal statute in question, 28 U.S.C. § 1915

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Cox v. The New York Racing Association, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cox-v-the-new-york-racing-association-ohsd-2025.