State of Oklahoma v. United States -Eastern District of Kentucky at Lexington

Circuit 6Dec 17, 2025

Split Score

SplitScore: 68/100

Case Summary

Disposition

Affirmed

The Sixth Circuit, on remand from the Supreme Court, rejected facial non-delegation and anti-commandeering challenges to the Horseracing Integrity and Safety Act. Relying heavily on FCC v. Consumers’ Research, the court held that because the Federal Trade Commission retains ultimate authority to modify or abrogate the Horseracing Authority’s rules and sanctions, the Authority is subordinate to a federal agency and the Act is constitutional. It therefore affirmed the district court’s dismissal of the States’ suit.

View Full Opinion Document (PDF)

Circuit Split Identified

Legal Issue

Whether the Horseracing Integrity and Safety Act's enforcement provisions unconstitutionally delegate executive power to a private entity in violation of the private non-delegation doctrine.

Circuit Positions

Circuit 6(this circuit)Circuit 8

Act is constitutional – Horseracing Authority is subordinate to the FTC; no private non-delegation violation.

Circuit 5

Act is unconstitutional – enforcement provisions give private entity final executive power, violating the private non-delegation doctrine.

Conflict Summary

The Fifth Circuit held that the Act’s enforcement provisions violate the private non-delegation doctrine because the Horseracing Authority wields federal enforcement power "without the FTC’s say-so." In contrast, the Sixth and Eighth Circuits concluded that the amended Act is constitutional because the Federal Trade Commission retains final authority to review, modify, or reject the Authority’s rules and sanctions, rendering the Authority subordinate to the agency.

Parties & Counsel

Parties

Appellant:State of Oklahoma, et al.
Appellee:United States of America; Horseracing Integrity and Safety Authority, Inc.; Federal Trade Commission; et al.

Legal Counsel

Appellant:Lochlan F. Shelfer – Gibson, Dunn & Crutcher LLP (lead); additional counsel from Oklahoma, West Virginia, Louisiana Attorneys General and private firms
Appellee:Courtney L. Dixon – U.S. Department of Justice (Federal Appellees); Pratik A. Shah – Akin Gump Strauss Hauer & Feld LLP (Authority Appellees)