KalshiEX LLC v. Matthew Schuler -Southern District of Ohio at Columbus

Circuit 6Sep 25, 2026

Split Score

SplitScore: 57/100

Case Summary

Disposition

Affirmed in Part

The Sixth Circuit addressed whether KalshiEX’s sports-event contracts, traded on its federally registered designated contract market, qualify as “swaps” under the Commodity Exchange Act (CEA) and therefore place the contracts exclusively under the Commodity Futures Trading Commission’s jurisdiction, pre-empting Ohio and Tennessee sports-gambling laws. The court held that the contracts do not meet the statutory definition of a swap and, even if they did, the CEA neither expressly nor impliedly pre-empts the two States’ gambling regimes; it therefore affirmed the Ohio district court’s refusal to enjoin state enforcement, vacated the Tennessee district court’s contrary injunction, and remanded both cases.

View Full Opinion Document (PDF)

Circuit Split Identified

Legal Issue

Whether sports-event contracts offered on federally regulated designated contract markets are “swaps” under 7 U.S.C. §1a(47) such that the CEA grants the CFTC exclusive jurisdiction and pre-empts state sports-gambling laws.

Circuit Positions

Circuit 3

Sports-event contracts are swaps; CEA expressly/implicitly pre-empts state gambling laws.

Circuit 6(this circuit)Circuit 9

Sports-event contracts are not swaps; CEA does not pre-empt state gambling laws.

Conflict Summary

The Third Circuit concluded that sports-event contracts are swaps and that the CEA’s exclusive-jurisdiction clause and Special Rule conflict-pre-empt state gambling regulation, whereas the Ninth and Sixth Circuits have held that such contracts are not swaps and that the CEA leaves room for, and does not pre-empt, state gambling laws governing sports wagering.

Parties & Counsel

Parties

Appellant:KalshiEX LLC
Appellee:Matthew T. Schuler et al. (Ohio officials); William Orgel et al. (Tennessee officials)

Legal Counsel

Appellant:Milbank LLP (William E. Havemann, Neal K. Katyal, et al.)
Appellee:Office of the Ohio Attorney General (Mathura J. Sridharan et al.); Office of the Tennessee Attorney General (Aaron L. Bernard et al.)