National Collegiate Athletic Ass'n v. Christie
926 F. Supp. 2d 551
D.N.J.2013Background
- Leagues filed a complaint in 2012 seeking to stop New Jersey's Sport Wagering Law and requested summary judgment and a preliminary injunction.
- Defendants challenged PASPA (federal law) as unconstitutional; NJTHA and Legislative Intervenors later intervened.
- Court noted PASPA grandfathering provisions and New Jersey's 2012 Sports Wagering Law aiming to authorize sports wagering.
- DOJ intervened with a brief on constitutionality; the Court heard oral argument in 2013 and granted summary judgment to the Leagues with a permanent injunction.
- Court held PASPA constitutional under the Commerce Clause, and preemption barred New Jersey's Sports Wagering Law, issuing a permanent injunction against such wagering.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether PASPA comports with the Commerce Clause | Leagues argue PASPA valid under Commerce Clause. | Defendants claim PASPA exceeds Congress's Commerce Clause powers and discriminates. | PASPA constitutional; rational basis satisfied. |
| Grandfathering clause' compatibility with Commerce Clause | Grandfathered states’ reliance supports constitutionality. | Grandfathering creates discrimination among states. | Grandfathering passes rational basis review; constitutional. |
| Anti-Commandeering/ Tenth Amendment concerns | PASPA does not compel state action; it prohibits state authorization of sports betting. | PASPA commandeers state regulatory processes. | PASPA does not violate the Anti-Commandeering principle; constitutional. |
| Due Process and Equal Protection | PASPA is rationally related to stopping spread of gambling; no fundamental rights implicated. | Grandfathering and disparate treatment raise equal protection concerns. | PASPA satisfies rational basis review; constitutional. |
| Equal Footing Doctrine | NJTHA claims Equal Footing requires differently situated states to be treated equally. | Equal Footing doctrine not applicable to this federal regulation case. | Court declines expansion; PASPA constitutional. |
Key Cases Cited
- New York v. United States, 505 U.S. 144 (U.S. 1992) (limits on Congress directing states to regulate or regulate through state compliance)
- Printz v. United States, 521 U.S. 898 (U.S. 1997) (anti-commandeering of state officers to implement federal programs)
- Reno v. Condon, 528 U.S. 141 (U.S. 2000) (DPPA not violative of Tenth Amendment; common framework for federal regulation)
- Morales v. Trans World Airlines, Inc., 504 U.S. 374 (U.S. 1992) (preemption / federal regulation of interstate commerce)
- Hodel v. Indiana, 452 U.S. 314 (U.S. 1981) (commerce power rational basis interpretation; cooperative federalism)
- United States v. Parker, 108 F.3d 28 (3d Cir. 1997) (deference to congressional findings on interstate commerce)
- United States v. Lopez, 514 U.S. 549 (U.S. 1995) (recognizes limits of Commerce Clause)
- Minnesota v. Clover Leaf Creamery Co., 449 U.S. 456 (U.S. 1981) (equal protection and grandfathering rationales in regulation)
- South Carolina v. Baker, 485 U.S. 505 (U.S. 1988) (Tenth Amendment structural considerations and federal-state balance)
- Coyle v. Smith, 221 U.S. 559 (U.S. 1911) (equal footing / state sovereignty considerations)
- Office of the Commissioner of Baseball v. Markell, 579 F.3d 293 (3d Cir. 2009) (PASPA rational basis and Grandfathering recognized)
- National League of Cities v. Usery, 426 U.S. 833 (U.S. 1976) (early Tenth Amendment framework on federal-state balance)