Murphy v. National Collegiate Athletic Association

Murphy v. National Collegiate Athletic Association was a landmark decision by the Supreme Court of the United States that struck down a federal law prohibiting states from authorizing sports gambling. The case centered on the constitutionality of the Professional and Amateur Sports Protection Act of 1992, a statute that effectively banned commercial sports betting nationwide with limited exceptions. In a 6-3 ruling, the Court held that PASPA violated the Tenth Amendment's anticommandeering doctrine by impermissibly directing state legislatures. The decision had an immediate and profound impact, opening the door for states across the United States to legalize and regulate sports wagering.

Background and legal context

The legal conflict originated from efforts by the State of New Jersey, led by Governor Chris Christie and later Governor Phil Murphy, to legalize sports betting at the state's casinos and racetracks. This state legislation directly challenged the federal Professional and Amateur Sports Protection Act, which had been championed by figures like Senator Bill Bradley and made it unlawful for a state to "sponsor, operate, advertise, promote, license, or authorize" sports gambling. The National Collegiate Athletic Association, along with major professional leagues including the National Football League, the National Basketball Association, the Major League Baseball, and the National Hockey League, sued to enjoin New Jersey's law. After the United States Court of Appeals for the Third Circuit ruled against New Jersey, the state petitioned for a writ of certiorari, which was granted by the Supreme Court of the United States.

Supreme Court decision

On May 14, 2018, the Supreme Court issued its decision, reversing the judgment of the Third Circuit and declaring the relevant provision of PASPA unconstitutional. The majority opinion, authored by Justice Samuel Alito, was joined in full or in part by Chief Justice John Roberts and Justices Anthony Kennedy, Clarence Thomas, Elena Kagan, and Neil Gorsuch. The Court's ruling focused on the structural protections of federalism embedded in the Constitution of the United States, specifically the anticommandeering principle established in prior cases like *New York v. United States* and *Printz v. United States*.

Majority opinion

Justice Samuel Alito's majority opinion systematically dismantled PASPA. The Court held that the law's core prohibition—commanding states to maintain their existing prohibitions on sports gambling—violated the anticommandeering rule of the Tenth Amendment. Alito reasoned that while Congress could regulate sports gambling directly under its powers enumerated in Article I, it could not conscript state legislatures as its regulatory agents. The opinion rejected the arguments of the Solicitor General of the United States and the sports leagues that PASPA merely established a federal standard states could choose to follow, finding it instead issued an affirmative command to state governments.

Concurring and dissenting opinions

Justice Clarence Thomas filed a concurring opinion, reiterating his longstanding view that the anticommandeering doctrine is rooted in the original understanding of the Constitution of the United States. Justice Neil Gorsuch also concurred, writing separately to emphasize the doctrine's role in preserving political accountability. Justice Stephen Breyer authored a dissenting opinion, joined in part by Justices Sonia Sotomayor and Ruth Bader Ginsburg. Breyer argued that PASPA did not commandeer states but permissibly preempted state law under the Supremacy Clause, drawing analogies to other federal preemption schemes like those involving the Food and Drug Administration.

Impact and implications

The immediate impact of *Murphy* was the rapid legalization of sports betting by numerous states, including New Jersey, Pennsylvania, Nevada, and Illinois. It catalyzed a multibillion-dollar industry, involving major gaming companies like Caesars Entertainment and DraftKings, and prompted new regulatory frameworks. The decision also reinforced federalism jurisprudence, significantly strengthening the anticommandeering doctrine and limiting the power of Congress to compel state legislative action. Its principles have been cited in subsequent legal debates over state cooperation with federal policies on issues ranging from marijuana enforcement to sanctuary city laws.

Category:United States Supreme Court cases Category:United States sports law Category:2018 in United States case law