● Live Wisconsin AG suit vs Kalshi & Polymarket pending · NY/IL insider-trading orders in effect · Updated May 2026
← United States Guide ● Litigation tracker · Updated September 19, 2026

Federal vs State
The Litigation Scoreboard

Eleven states are in active litigation over who regulates prediction markets. Kalshi has lost five of six PI rulings: Arizona went to the CFTC (May), but Michigan (June), Nevada (May), New York (July 7), Washington (July 21), and Connecticut (August 11) all went against the platforms. Minnesota went to the CFTC — Judge Katherine Menendez blocked the state's felony ban on July 27. The Connecticut ruling introduced a new legal theory: sports event contracts are not statutory "swaps" under the CEA, because they depend on event outcomes rather than whether an event occurs — directly conflicting with the Third Circuit's April ruling that they ARE swaps. New York escalated further: AG Letitia James and Governor Kathy Hochul filed a separate state lawsuit on July 31 seeking at least $36 billion in damages. The Second Circuit now holds two Kalshi appeals (NY + CT) that may be consolidated. Supreme Court review is increasingly likely. This page tracks every case in one place.

States in litigation
14
CFTC wins
2
Pending
5
State wins
6

Every active case, newest development first


Missouri C&D issued — 30 days to comply N/A (pre-litigation)
State action · AG Catherine Hanaway

Sent cease-and-desist letters September 18, 2026 to six prediction market operators — Kalshi, Polymarket, Robinhood, Crypto.com, Novig, and Underdog — alleging their sports event contracts constitute unlicensed sports wagering under Missouri law. The broadest single-state multi-platform enforcement action to date.

Federal response

No CFTC action filed yet. Compliance window runs until approximately October 18, 2026; if platforms do not comply, Missouri would need to file suit, and the Eighth Circuit would become the next circuit to hear the preemption question.

LATEST September 18: AG Hanaway issued simultaneous C&D letters to all six major CFTC-registered prediction market operators. 30-day compliance window ends approximately October 18. Platforms that do not comply or obtain Missouri Gaming Commission licenses face state enforcement action. Missouri is the first state to target all major operators simultaneously rather than sequentially.
Montana Enforcement paused — joint stipulation US District Court, D. Mont. (dismissed)
State action · MT Gambling Control Division (AG office)

Montana Gambling Control Division issued C&D letters to Kalshi (April 2026) alleging sports event contracts were unlicensed gambling under Montana law. Kalshi counter-sued in federal court.

Federal response

Kalshi filed federal suit challenging Montana's C&D letters. Both sides reached a joint stipulation filed September 17, 2026: Kalshi dismissed its lawsuit; Montana agreed to pause all enforcement.

LATEST September 17: Joint stipulation filed — Kalshi dismissed its suit; Montana agreed to pause all enforcement, investigations, and C&D proceedings against Kalshi's event contracts. Pause lasts until the Ninth Circuit denies en banc review or issues a full-court decision. Montana must give Kalshi 30 days written notice before resuming enforcement after that window closes.
Nevada State won (PI + contempt) First Judicial District, Nevada (state court)
State action · Nevada Gaming Control Board

NGCB obtained a May 18, 2026 preliminary injunction requiring Kalshi to geofence sports, elections, and entertainment event contracts from Nevada users. Nevada Supreme Court denied Kalshi's bid to pause the order.

Federal response

No CFTC suit filed in Nevada. Kalshi is contesting the injunction in Nevada state court while simultaneously facing contempt proceedings for alleged non-compliance.

LATEST August 28: Ninth Circuit ruled 3-0 against Kalshi (sports contracts not swaps, states can regulate). September 9: Kalshi filed en banc petition asking full 11-judge Ninth Circuit to overturn the panel ruling. Simultaneously Robinhood filed a separate SCOTUS cert petition from the same ruling. New Jersey already filed a SCOTUS cert petition September 2 from the Third Circuit loss. Two SCOTUS petitions now pending; Kalshi en banc decision expected weeks to months.
Michigan State won (PI denied) US District Court, W.D. Mich. → 6th Cir.
State action · AG Dana Nessel

Sued Kalshi alleging illegal online sports betting. Polymarket and Robinhood counter-sued seeking a preliminary injunction on CFTC-preemption grounds.

Federal response

Polymarket/Robinhood PI DENIED June 19 by Judge Paul Maloney, who held sports event contracts are likely NOT swaps and that CFTC authority would intrude on traditional state regulation.

LATEST TRO extended July 13: $500K/day fine, August 12 GeoComply deadline (passed). Kalshi operating under CFTC emergency order. September 4: Robinhood reached court-approved stipulation with Michigan — stops new sports contracts by Sept 9, closes positions by Oct 9; Michigan pauses enforcement against Robinhood. Kalshi continues under CFTC protection. Six Sixth Circuit appeals pending (Robinhood, Polymarket, Coinbase, Kalshi).
Arizona CFTC won (PI granted) US District Court, D. Ariz.
State action · AG Kris Mayes

20 misdemeanor counts against Kalshi (March 2026) over election and sports contracts.

Federal response

CFTC sued; TRO April 10; preliminary injunction May 5 (Judge Liburdi) on three independent preemption grounds: field, conflict, impossibility.

LATEST May 5 PI in force (Judge Liburdi). August 28: Ninth Circuit ruled 3-0 against Kalshi in the Nevada case — directly undermining the preemption theory that Arizona PI relied on. Arizona AG Kris Mayes reviewing the Ninth Circuit opinion and its effect on the Arizona injunction; revival of the 20 misdemeanor charges is possible.
Connecticut State won (PI denied) US District Court, D. Conn. → 2nd Cir.
State action · Dept. of Consumer Protection

C&D notices issued December 2, 2025 to Kalshi, Robinhood, and Crypto.com for unlicensed sports wagering. Kalshi filed suit the following day seeking a preliminary injunction.

Federal response

CFTC sued Connecticut in April 2026, arguing CEA preemption. Kalshi filed its own separate PI motion in December 2025.

LATEST Federal: PI denied August 11 (Judge Oliver, "not a swap") — on appeal to 2nd Circuit. August 27: CT AG Tong + Governor Lamont filed a separate state court suit in CT Superior Court seeking injunction + disgorgement. Ex parte TRO denied. Kalshi counter-sued August 28. Two simultaneous CT proceedings now active. Ninth Circuit's August 28 ruling provides persuasive authority for the state court action.
Washington State won (PI granted) King County Superior Court (state court)
State action · WA Attorney General / WA Gambling Commission

Washington Gambling Commission sent Kalshi a notice that offering event-based contracts was not authorized under state law. Kalshi did not comply. AG sought and obtained a preliminary injunction.

Federal response

No separate CFTC suit filed in Washington. McHale rejected Kalshi's CFTC-preemption argument directly. Injunction terms still being negotiated — both sides asked to submit a compliance plan by the first week of August.

LATEST August 13: Judge McHale issued final compliance order expanding the injunction — sports, elections, politics, entertainment, culture, tech/science, and "mentions" markets must all stop. Commodities, climate, economics, and finance contracts are exempt. IP geofence required by August 19; multi-source commercial geofencing by September 2 ($120K/day fine). Washington Court of Appeals denied Kalshi's stay request. September 2 deadline falls two days before the NFL regular season opens.
New York State won (PI denied) US District Court, S.D.N.Y. + 2nd Cir.
State action · NY Gaming Commission / AG Letitia James

Sent Kalshi a cease-and-desist in 2025, alleging sports gambling without a state license. NY is the largest legal sports-betting market in the US.

Federal response

CFTC sued New York in May 2026. Separately, Kalshi filed its own suit (KalshiEX LLC v. Williams) seeking a PI — denied July 7 by Judge Analisa Torres, who ruled the CEA does not preempt NY gambling law under field, conflict, or impossibility preemption. Kalshi appealed to the Second Circuit the same day.

LATEST Kalshi PI denied July 7 (Judge Torres, SDNY). July 31: NY AG Letitia James and Governor Kathy Hochul filed a separate state lawsuit accusing Kalshi of operating an unlicensed gambling business and allowing 18-20 year olds to participate in violation of state 21+ requirements. NY is seeking at least $36 billion in damages, penalties, and related relief. Kalshi appealed the PI denial to the 2nd Circuit.
Minnesota CFTC won (PI granted) US District Court, D. Minn.
State action · Gov. Tim Walz / AG Keith Ellison

SF 4760 signed May 19, 2026 — first state felony ban on prediction-market operators, effective August 1, 2026.

Federal response

CFTC sued May 20 seeking preliminary injunction before the effective date. Kalshi and Polymarket US also filed separately.

LATEST PI granted July 27 (Judge Katherine Menendez, D. Minn.) — blocked enforcement of Minnesota's felony ban against CFTC-registered DCMs. Judge found plaintiffs likely to succeed on federal preemption at preliminary stage, but noted different contract types may require separate analysis. Kalshi, Polymarket US, and other DCM-registered platforms remain accessible.
New Mexico CFTC suit pending US District Court, D.N.M.
State action · AG Raúl Torrez

Sued Kalshi (early June 2026) alleging its sports event contracts are unlicensed online sports betting. NM permits sports betting only at tribal casinos under state-tribal compacts.

Federal response

CFTC sued New Mexico June 12. Polymarket filed its own independent federal suit July 1 seeking declaratory judgment and a preliminary injunction — after New Mexico rejected two requests to delay enforcement pending the Kalshi case.

LATEST Polymarket filed independent federal suit July 1 — its first direct preemption litigation without the CFTC. Both the CFTC and Polymarket suits are now pending in D.N.M.
Rhode Island Three cases on the docket US District Court, D.R.I. + RI Superior Court
State action · AG Peter F. Neronha

State-court suits against Kalshi and Polymarket (May 26) alleging sports contracts are illegal sports betting; seeks disgorgement.

Federal response

Kalshi counter-sued in federal court the same day; CFTC filed its own complaint May 29 plus a motion to intervene.

LATEST CFTC complaint filed May 29. Chairman Selig called the state suits an "onslaught" and a "power grab."
Massachusetts State won (PI granted) Suffolk County Superior Court → Massachusetts Supreme Judicial Court (SJC)
State action · AG Andrea Campbell

Sued Kalshi September 2025 — the first state in the country to sue a prediction market operator — alleging sports event contracts constitute unlicensed sports wagering under Massachusetts law.

Federal response

CFTC filed amicus brief April 24, 2026 asserting exclusive federal jurisdiction over Kalshi's event contracts. A coalition of 38 state AGs filed an opposing amicus brief on April 28 supporting Massachusetts.

LATEST Superior Court PI granted January 20, 2026 (Judge Barry-Smith), blocking Kalshi's sports contracts. Kalshi appealed directly to the SJC. Oral arguments May 5, 2026 — court appeared skeptical of Kalshi's CFTC-preemption argument. SJC waived its 130-day decision deadline (which would have fallen in mid-September); ruling still pending as of September 2026. Will be the first state supreme court decision on prediction markets anywhere in the US.
Illinois CFTC suit pending US District Court, N.D. Ill.
State action · Gov. JB Pritzker

Executive order (May 2026) directing state agencies to pursue enforcement against prediction-market operators.

Federal response

CFTC sued Illinois in April 2026 to block state enforcement.

LATEST CFTC suit pending; agency citing the Arizona preliminary injunction as persuasive authority.
Wisconsin Cross-suits pending US District Court, W.D. Wis. + WI state court
State action · AG Josh Kaul

Sued Kalshi, Polymarket, Robinhood, Crypto.com and Coinbase in state court (late April 2026) seeking permanent injunctions.

Federal response

CFTC counter-sued Wisconsin in federal court April 28 to reaffirm exclusive jurisdiction.

LATEST Both actions pending. Broadest state suit to date — five platforms named.

Three things that decide how this ends


1. The CFTC's proposed rule

CFTC proposed prediction-markets rule published in the Federal Register June 12, 2026 — a 267-page NPRM that would permit most sports event contracts (scores, spreads, win-loss, stats) while banning single-play, injury, officiating, and pre-collegiate contracts. 45-day comment window closes July 27. A formal regulatory regime strengthens every preemption argument the agency is making in court.

2. The White House position

President Trump posted public support for CFTC exclusive jurisdiction in late May 2026, reversing his April "casino" comment.

3. The copycat pipeline

At least 15 state legislatures introduced prediction-market bills in 2026. Massachusetts and New Jersey have similar measures in committee, watching the litigation before moving. With district courts now split — Arizona for the CFTC, Michigan for the state — the first appellate ruling (the Sixth Circuit is positioned to move first after the June 19 Michigan decision) sets the template every other legislature follows or abandons.