West Flagler Associates, Ltd. v. Debra Haaland, No. 21-5265 (D.C. Cir. 2023)
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The Seminole Tribe of Florida (“Tribe”) and the State of Florida entered into a compact under the Indian Gaming Regulatory Act (“IGRA”). That gaming compact (“Compact”) purported to permit the Tribe to offer online sports betting throughout the state. The Compact became effective when the Secretary of the Interior failed to either approve or disapprove it within 45 days of receiving it from the Tribe and Florida. The Plaintiffs, in this case, brick-and-mortar casinos in Florida, object to the Secretary’s decision to allow the Compact to go into effect because, in their view, it violated IGRA. They also believe that the Compact violates the Wire Act, the Unlawful Internet Gambling Enforcement Act, and the Fifth Amendment and that the Secretary was required to disapprove the Compact for those reasons as well. The district court denied the Tribe’s motion and granted summary judgment for Plaintiffs.
The DC Circuit reversed and remanded with instructions to enter judgment for the Secretary. The court explained that IGRA does not prohibit a gaming compact—which is, at bottom, an agreement between a tribe and a state—from discussing other topics, including those governing activities “outside Indian lands.” Accordingly, the court explained that the district court erred by reading into the Compact a legal effect it does not (and cannot) have, namely, independently authorizing betting by patrons located outside of the Tribe’s lands. The court held only that the district erred by reading into the Compact a legal effect it does not (and cannot) have, namely, independently authorizing betting by patrons located outside of the Tribe’s lands.
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