Photo by Michał Parzuchowski on Unsplash
Bailey Wharton, Associate Member, University of Cincinnati Law Review
Sports betting and professional sports leagues are no longer in two separate spheres. In the last half decade, all five of the major professional sports leagues – the National Hockey League, National Football League, National Basketball Association, Major League Baseball, and Major League Soccer – have gone all in on merging professional sports and sports betting. The Leagues themselves, individual teams, and even individual athletes are signing lucrative sponsorships and partnerships with sportsbooks and casinos. While betting on sports is as easy as ever, these Leagues have also run into issues with athletes betting on their own sport.
Part II details a brief history of the legalization of sports betting in both Canada and the United States. This Part also overviews each of the five Leagues’ relationships with sports betting and the gambling policies of each sport. Part III discusses how the various Leagues have handled recent incidents involving players betting on their sport, the discrepancies in discipline by different Leagues, and what the Leagues must do going forward to protect their sports and players in a world where sports betting is so easy.
A. History of Legal Sports Betting in the U.S. and Canada
i. Sports Betting in Canada
On June 23, 2021, the Canadian Parliament passed Bill C-218, legalizing single-game sports betting. While parlay betting, casino games, and lotteries have long been legal in Canada and run and regulated by provincial lottery commissions, this is the first time single-game wagering has been explicitly legalized. With the passage of this bill, it is now up to each province to legalize and regulate single-game betting as they choose. The first province to do so was Ontario with the introduction of PROLINE+ sportsbook on August 27, 2021, the day C-218 went into effect. Quebec and British Colombia’s lottery commissions also began offering single-game betting on August 27, 2021. The Western States Lottery Corporation, which operates in Alberta, Manitoba, and Saskatchewan, updated their sportsbook, SPORT SELECT, on November 1, 2021, to offer single-game betting. New Brunswick, Prince Edward Island, and Newfoundland and Labrador were granted access to single-game wagering on the Atlantic Lottery Corporation’s (ALC) betting platform shortly after the law went into effect on August 27, 2021, while Nova Scotia is the most recent province to get access to single-game betting on ALC’s platform on February 11, 2022.
ii. Sports Betting in the U.S.
When the Supreme Court overturned the Professional and Amateur Sports Protection Act of 1992 (PASPA), it “opened the floodgates to state-by-state legalization and regulation of sports betting.” Prior to PASPA’s repeal, sports betting was banned everywhere except in Nevada. However, the Court’s ruling in Murphy v. NCAA, the case in which PASPA was ultimately repealed, opened the door for individual states to legalize sports betting. Since the end of PASPA, thirty-four states have legalized sports betting. Twenty-one states offer both online and brick and mortar sportsbooks, while nine states offer just brick and mortar sportsbooks and two states offer just online sportsbooks.
B. Relationship Between Professional Sports and Sports Betting
i. National Hockey League (NHL)
Historically, the NHL’s stance has always been against sports betting. In fact, Commissioner Gary Bettman has been on record stating that sports betting was “inconsistent” with “the atmosphere” the League seeks to create. However, Commissioner Bettman’s view on the matter appeared to change after the death of PASPA in 2018, and the NHL announced their first betting sponsorship with MGM Resorts to be “an official betting partner.” Since 2018, the NHL has partnered with ten betting entities, both in North America, as well as several partnerships with European-based companies to operate in the Baltic region, Russia, and German and Austrian regions. The NHL has also partnered with the American Gaming Association’s program to promote responsible gambling.
Eight out of the thirty-two teams have one official sports betting partner, while there are seven teams that have two or more sports betting partners. The Washington Capitals and New Jersey Devils have in-arena sports books, while the United Center, where the Chicago Blackhawks play, has plans to build an in-arena sports book soon. Bet99 is a home helmet sponsor of the Ottawa Senators and starting in the 2022-2023 season, the Washington Capitals will have the Caesars casino logo on their jerseys. The NHL also has two players with individual brand sponsorship deals with betting companies. Auston Matthews, of the Toronto Maple Leafs, was the first active NHL player to sign with a betting company when he partnered with Bet99, and Connor McDavid, of the Edmonton Oilers, became the first professional athlete to become a brand ambassador for a betting company when he signed with BetMGM.
Despite the influx of gambling money into the NHL and the multitude of partnerships between betting companies, the League, the teams, and the players, the CBA is particularly bare when it comes to its discussion on the rules for players when it comes to sports betting. In fact, the only mention of gambling in the entire CBA is its stance that “[g]ambling on any NHL Game is prohibited.”
ii. National Football League (NFL)
Similarly to the NHL, the NFL’s long held view was that sports betting is “a threat to the integrity of [the] [L]eague and contrary to the public good.” But also like the NHL, the NFL changed its tune after the end of PASPA. In 2021, the NFL announced partnerships with DraftKings, FanDuel, and Caesars to the tune of almost a billion dollars. The NFL later added sponsorship deals with BetMGM, WynnBET, Fox Bet, and PointsBet.
Thirteen of the thirty-two teams have one official sports betting partner, and nine teams have two or more betting partners. BetMGM and the Arizona Cardinals plan to have an in-stadium sportsbook up and running for the start of the 2022-2023 season and Betfred USA Sports plans to open a sports betting lounge right outside the Denver Broncos stadium.
The NFL’s CBA states that as part of an NFL player contract, a player “acknowledges his awareness that if he bets on an NFL game [or] knowingly associates with gamblers or gambling activity…the Commissioner will have the right…to fine…, to suspend…for a period certain or indefinitely, and/or to terminate [the player’s] contract.”
Additionally, in 2018, the NFL distributed its Gambling Policy, emphasizing that “[g]ambling, particularly on NFL games or other sports, presents potential risks to the integrity of our competition and can negatively impact team cohesion.” The policy further states that all NFL personnel are prohibited from betting on NFL games, practices, or events, and all NFL personnel other than players, are prohibited from betting on other sports. Thus, NFL players are allowed to bet on sports, just not on football.
iii. National Basketball Association (NBA)
Currently, the NBA has partnerships with six authorized gaming operators – FanDuel, DraftKings, MGM Resorts, The Stars Group, TheScore, and Bally’s. Ten of the thirty teams have one official betting partner, whereas six teams have two or more betting partners. FanDuel has an in-arena sportsbook at Footprint Arena, home of the Phoenix Suns, and the Chicago Bulls, Cleveland Cavaliers, and Houston Rockets all have plans to open in-arena sportsbooks in the near future. While no active NBA players have individual brand deals with any sports betting entities, FanDuel has a partnership with a company called Boardroom, which is co-owned by Kevin Durant.
The NBA’s Constitution and By-Laws, which govern “all Players in the Association,” states that “[a]ny Player who, directly or indirectly, wagers money or anything of value on the outcome of any game played by a Team in the [L]eague operated by the Association shall, on being charged with such wagering, be given an opportunity to answer such charges after due notice, and the decision of the Commissioner shall be final, binding and conclusive and unappealable. The penalty for such offense shall be within the absolute and sole discretion of the Commissioner and may include a fine, suspension, expulsion and/or perpetual disqualification from further association with the Association or any of its Members.”
In addition, the NBA’s CBA has a provision stating that “[a]ll players shall be required each Season to attend and participate in one (1) anti-gambling training session conducted by their Team and/or the NBA,” with failure to do so resulting in a $20,000 fine.
iv. Major League Baseball (MLB)
The MLB has partnered with nine domestic gaming operators, as well as with Betcris, which is the MLB’s wagering operator in Latin America. While there are ten teams with one official sports betting partner, there are only two teams which have two or more betting partnerships. This means that fewer than half of all teams in the MLB have any sort of official sports betting partnerships.
Sports betting was an important topic discussed in the MLB and MLBPA’s recent CBA negotiation, as there are several new provisions included that relate directly to sports betting. First, “all clubs will be required to institute enhanced ballpark safety measures [and] a hotline will be developed for the purpose of reporting threats made against players or their families relating to sports betting.” Second, “it shall be illegal for Major League Baseball and any club to sell and/or license a player’s confidential medical information, personal biometric data, or any nonpublic data used to evaluate player performance in practices or training sessions,” which seems to be a “pre-emptive strike at barring MLB or any team from selling such data to gambling-related companies.” Third, players will now have the ability to sign endorsements or become brand ambassadors for sports betting companies.
However, despite these new concessions in the 2022 CBA, there are still restrictions on MLB players’ ability to bet on sports. Rule 21 of the Official Professional Baseball Rules Book sets out the penalties for gambling misconduct. For example, an MLB player who bets on an MLB game for which they have “no duty to perform” will be suspended for one year, while an MLB player who bets on a game for which they do have “a duty to perform” will be permanently suspended.
v. Major League Soccer (MLS)
As it stands, the MLS remains the least integrated professional league in the sports betting partnership world. MLS itself only has one official gaming partner, and only eight of the twenty-eight teams have sponsorships with sports betting companies, none of whom have more than one partnership at this time. The Philadelphia Union is the first MLS team to discuss a stadium name deal with betting companies, and the Seattle Sounders are the first MLS team to have a casino logo sponsorship on their jerseys. Notably, the Chicago Fire is the first MLS team to “deliver problem gambling and gaming awareness sessions to teams throughout their organization.”
The MLS’s CBA states that “the Commissioner may terminate an [Standard Player Agreement]…at any time…if the Player bets, or has offered or attempted to bet, money…on any game participated in by any Team which is a member of MLS, or by any MLS Players, or on games of any National Team…[or] if the Player is involved in the giving or offering of any bribe that involves, or gambles on, any MLS game.”
A. Penalized Players
Today, sports betting is easier than ever due to the ability to place bets online. As a result, the number of sports bettors has exploded in recent years. Therefore, it is no surprise that professional sports leagues have run into issues of players making bets in violation of League CBAs and rules. Over the last ten years, there have been a number of professional athletes who have been investigated for gambling-related allegations or have faced gambling-related penalties from their respective Leagues.
Most recently, Atlanta Falcon’s player Calvin Ridley was suspended indefinitely, and at least through the entirety of the 2022-2023 NFL season, for placing bets on NFL games in violation of the NFL CBA and Gambling Policy. In 2019, former Arizona Cardinals player Josh Shaw received an indefinite suspension by the League for “a three-team parlay bet involving the Arizona Cardinals.” Although Shaw was officially reinstated in March of 2021, he does not currently have a contract with any NFL team.
In October 2021, MLS’s Sporting Kansas City (SKC) player Felipe Hernandez was suspended “without pay for the remainder of 2021 due to violations of the [L]eague’s gambling integrity rules and standards of conduct” after it was discovered that he was “engaged in extensive and unlawful sports gambling while a member of [SKC] that included placing wagers on two MLS matches.”
While it has been several decades since the last confirmed gambling scandal in the NHL, in 2021, the League was forced to investigate allegations that former San Jose Sharks player Evander Kane was betting on NHL games, including allegations, made by his estranged wife, that he “bet on Sharks games ‘with bookies’ and threw games for gambling purposes.” However, after a League investigation, Kane was ultimately cleared of all allegations.
B. Discrepancy in Gambling Penalties Among the Leagues
Based on the severity of punishments dished out to those athletes caught betting on games, the Leagues take sports betting violations very seriously. However, the Leagues clearly do not adhere to a uniform penalty scheme when it comes to disciplining players for betting on their sport. This is primarily due to the fact that each Commissioner has varying levels of authority to dish out penalties. For example, the NBA Commissioner has near absolute authority to determine the type and severity of penalties, while the MLB Rules Book delineates specific penalties for certain types of gambling violations. As a result, it would be nearly impossible for there to be any form of intra-sport guidelines on how to uniformly handle sports betting issues.
C. Leagues’ Responsibilities to Protect Players
As professional sports leagues continue to entangle with sports betting companies and move teams to Las Vegas, the problem of players betting on sports is most likely going to get worse and more common because “[p]ro athletes are in the exact demographic outlets like FanDuel and Draft Kings covet the most – males in their 20s and 30s who have expendable income.”
Therefore, it is the responsibility of each League to ensure that they are doing everything in their power to set their players up for success, whether that comes in the form of mandatory anti-gambling programs (like in the NBA), on-staff financial advisors to serve as a trusted resource for players to go to for advice on how to gamble responsibly, or robust player assistance programs for players needing additional addiction resources. It is in the best interest of the players to have access to these resources, and in the best interest of the Leagues to try at all costs to protect against a league-shattering gambling scandal that calls into question the integrity of sport.
As long as there are sports to bet on, people are going to bet on them, and as long as people are betting on sports, there is always a risk that a professional athlete will get caught up in the allure of gambling and threaten the integrity of professional sports. And while the threat of players betting on their sport is always looming, the windfall of revenue these professional sports leagues have seen since partnering with betting companies is just too great to ignore.
 Bill C-218, An Act to Amend the Criminal Code (Sports Betting) 2nd Session 43rd Parliament, 69-70 Elizabeth II (2020-2021); see Ted Dahlstrom, Canada Sports Betting – Legality, Launch Dates, And FAQ, Sports Handle (Feb. 25, 2022), https://bit.ly/3wJdlnm (C-218 “was a simple bill that would change the criminal code to make it explicitly lawful for provinces to administer and regulate single-game sports betting.”).
 Id. (“The federal government will not be regulating sports betting.”).
 See id. (starting April 4, 2022, “private gaming operators, registered with the AGCO and that have entered into an operating agreement with [iGaming Ontario], can start offering their games and services to players within the boundaries of Ontario.”); see also Geoff Zochodne, Single-Game Sports Betting is Legal in Canada. How Can You Wager?, Covers (Aug. 26, 2021, 9:48 AM), https://bit.ly/3ILtJWH.
 Dahlstrom, supra note 1.
 Geoff Zochodne, Single-Event Sports Betting Quietly Added to Lottery Game in Western Canada, Covers (Nov. 9, 2021, 12:58 PM), https://bit.ly/3Dk3jKK.
 Greg Warren, Single-Game Sports Wagering To Launch Friday in Nova Scotia, Sports Handle (Feb. 10, 2022), https://bit.ly/3DrRSkk.
 Chris Altruda, Legal US Sports Betting Revenue, Handle And Tax Totals Since PASPA Repeal, Sports Handle (Mar. 25, 2022), https://bit.ly/3uB5XYv.
 Id.; see also Jill R. Dorson, What Is PASPA, The Federal Ban on Sports Betting?, Sports Handle (July 1, 2020), https://bit.ly/36U3XlQ (Delaware, Montana, and Oregon “had certain quasi-sports betting games grandfathered in, meaning they could continue them,” but “only Nevada was able to license and regulate sports bets of all kind.”)
 Dorson, supra note 9.
 Brett Smiley, Legal Sports Betting Bill Tracker, Sports Handle (Dec. 6, 2021), https://bit.ly/3iJqRiF (Arizona, Arkansas, Colorado, Connecticut, Delaware, DC, Florida, Illinois, Indiana, Iowa, Louisiana, Maryland, Michigan, Mississippi, Montana, Nebraska, Nevada, New Hampshire, New Jersey, New Mexico, New York, North Carolina, North Dakota, Ohio, Oregon, Pennsylvania, Rhode Island, South Dakota, Tennessee, Virginia, Washington, West Virginia, Wisconsin, and Wyoming).
 Id. (While legal, sports betting is not yet live in Nebraska, North Dakota, or Ohio).
 Id. (Arizona, Arkansas, Colorado, Connecticut, DC, Illinois, Indiana, Iowa, Louisiana, Maryland, Michigan, Nevada, New Hampshire, New Jersey, New York, Ohio, Oregon, Pennsylvania, Rhode Island, Virginia, and West Virginia).
 Id. (Delaware, Mississippi, Montana, New Mexico, North Carolina, North Dakota, South Dakota, Washington, and Wisconsin).
 Id. (Tennessee and Wyoming).
 Darren Rovell, NHL announces betting sponsorship deal with MGM Resorts, ESPN (Oct. 29, 2018), https://es.pn/3iHluAm.
 See id. (MGM Resorts); NHL Public Relations, NHL, Betway announce multiyear partnership, NHL.com (May 14, 2021), https://bit.ly/3DlfHKp (Betway); NHL Public Relations, NHL announces official partner for sports betting, daily fantasy, NHL.com (Nov. 5, 2018), https://bit.ly/3IOSW2K (FanDuel); NHL Public Relations, NHL reaches sports betting partnership with PointsBet, NHL.com (Feb. 9, 2021), https://bit.ly/3JQMCJf (PointsBet); NHL Public Relations, NHL names Bally’s official sports betting partner, NHL.com (Feb. 18, 2021), https://bit.ly/3wKXOna (Bally’s); NHL Public Relations, NHL, William Hill announce multiyear partnership, NHL.com (Mar. 28, 2019), https://bit.ly/3wL8fXN (William Hill); NHL Public Relations, DraftKings agree to become sports betting, DFS, iGaming partner of NHL, NHL.com (Oct. 13, 2021), https://bit.ly/3tNlp4C (DraftKings).
 NHL Public Relations, NHL partners with betting brand OlyBet, NHL.com (June 3, 2021), https://bit.ly/3uz7Che (OlyBet).
 NHL Public Relations, NHL announces sports betting agreement with Liga Stavok, NHL.com (Sept. 22, 2021), https://bit.ly/36RDc1x (Liga Stavok).
 NHL Public Relations, NHL, Interwetten announce multiyear partnership, NHL.com (Jan. 25, 2022), https://bit.ly/3Di93ET (Interwetten).
 NHL Public Relations, NHL partners with AGA to promote responsible sports betting, NHL.com (Oct. 23, 2020), https://bit.ly/3JNfAtG.
 Chris Murphey, Anaheim Ducks expands partnership with San Manuel Casino, SBC Americas (Oct. 9, 2019), https://bit.ly/3iL4V6N (Anaheim Ducks and San Manuel Casino); Arizona Coyotes, SaharaBets Teams Up with Coyotes as Official Sports Betting Partner, NHL.com (Jan. 5, 2022), https://bit.ly/3wKGnD0 (Arizona Coyotes and Sahara Bets); Sabres Press Release, Sabres name FanDuel Group an official sports betting partner, NHL.com (Feb. 23, 2022), https://bit.ly/3LmrsmH (Buffalo Sabres and FanDuel); Kroenke Sports & Entertainment, PointsBet Partners with KSE as Official Gaming Partner of the Avalanche, NHL.com (Aug. 7, 2020), https://bit.ly/3wQND0e (Colorado Avalanche and PointsBet); Chris Murphy, Betway agrees six high-profile partnerships across NBA and NHL, SBC Americas (Mar. 25, 2021), https://bit.ly/3JTFMmc (Los Angeles Kings and Betway); Murphy, supra (New York Islanders and Betway); Cort Smith, NHL Ottawa Senators Strike Sponsorship Deal With Ontario, Canada Casino, Casino.org (Oct. 10, 2018, 4:15 PM), https://bit.ly/3Lrw62C (Ottawa Senators and Rideau Carleton Raceway Casino); Greg Warren, BCLC Targeting Canucks Fans With Prize-Loaded Promotion, Sports Handle (Jan. 10, 2022), https://bit.ly/3tOaeZu (Vancouver Canucks and British Columbia Lottery Corporation).
 The Detroit Red Wings have partnerships with BetMGM, DetroitRedWings.com, Detroit Red Wings renew and expand BetMGM strategic partnership, NHL.com (Oct. 28, 2020), https://bit.ly/3wIBQRL, FanDuel, Cole Rush, FanDuel Inks Sports Betting Partnerships with Detroit Tigers and Red Wings, Michigan Sharp (April 6, 2021), https://bit.ly/36woAoF, and Motor City Casino, Chris Murphy, FanDuel and MotorCity Casino agree gaming partnerships with Detroit’s Tigers and Red Wings, SBC Americas (April 6, 2021), https://bit.ly/3IQA2bM. The Nashville Predators have partnerships with Bally’s, Nashville Predators, Predators, Bally’s Corporation Announce Sports Betting Partnership, NHL.com (Oct. 21, 2021), https://bit.ly/3LpG4l8, and DraftKings, NashvillePredators.com, Predators Announce Partnership with Sports Betting Operator DraftKings, NHL.com (Dec. 10, 2020), https://bit.ly/3NHvFDF. The New Jersey Devils have partnerships with William Hill USA, New Jersey Devils, William Hill partners with New Jersey Devils and Prudential Center, NHL.com (Oct. 25, 2018), https://bit.ly/3uzNdsl, FanDuel, New Jersey Devils, NHL and the New Jersey Devils Enter Into Partnerships with FanDuel, NHL.com (Nov. 5, 2018), https://bit.ly/35q8TPi, and PlayUp, New Jersey Devils PR, RELEASE: Devils Announce Major Partnership with PlayUp, NHL.com (Jan. 14, 2021), https://bit.ly/3IQA838. The New York Rangers has partnerships with BetMGM, Jill R. Dorson, Caesars Partners with Knicks, Rangers, and Madison Square Garden, Sports Handle (Nov. 18, 2021), https://bit.ly/3qK2Zjw, Caesars, Dorson, supra, and DraftKings, Andrew Cohen, DraftKings Renews Deal to Continue As Rangers and Knicks Fantasy and Betting Partner, Sport Techie (Jan. 6, 2020), https://bit.ly/3JOVoaQ. The Philadelphia Flyers have partnerships with Betway, Philadelphia Flyers, Flyers announce new partnership with Super Group owned Betway, NHL.com (Nov. 9, 2021), https://bit.ly/371DIKE, and SugarHorse Casino, Philadelphia Flyers, Flyers and Wells Fargo Center Announce Official Sportsbook Partner, NHL.com (Sept. 4, 2019), https://bit.ly/36TlwCH. The Pittsburgh Penguins have partnerships with BetRivers.com and Rivers Casino. Pittsburgh Penguins, Rivers Casino Pittsburgh, BetRivers.com to Build Sportsbook-Style Lounge, NHL.com (Sept. 23, 2020), https://bit.ly/3qK1TUy. The Vegas Golden Knights have partnerships with BetMGM, Vegas Golden Knights, Vegas Golden Knights Renew And Extend Team Partnership with BetMGM, NHL.com (Dec. 2, 2021), https://bit.ly/3LrwFtg, William Hill USA, Vegas Golden Knights, William Hill US & VGK Form 1st Partnership Between Sports Book & NHL Team, NHL.com (Sept. 18, 2018), https://bit.ly/3qLfxXM, and Caesars, Vegas Golden Knights, Vegas Golden Knights Extend Team Partnership With Caesars Entertainment, NHL.com (Mar. 4, 2022), https://bit.ly/3JVvDFJ.
 Elliotte Friedman, 32 Thoughts: Unafraid Auston Matthews takes big off-ice step, Sportsnet (Feb. 1, 2022, 11:43 AM), https://sprtsnt.ca/3Ll5kcm.
 Senators make Bet99 first gambling company on helmets, Sports Business Journal (Dec. 8, 2021), https://bit.ly/36EXNq1.
 Washington Capitals, Caps Announce Caesars Entertainment as First-Ever Jersey Patch Partner, NHL.com (Sept. 24, 2021), https://bit.ly/3DgMrod.
 See Auston Matthews first active NHL player to sign with betting company, Sports Business Journal (Feb. 2, 2022), https://bit.ly/3uDH3r5; see also Friedman, supra note 26.
 See Sam Profeta, BetMGM Partners With Edmonton Oilers Star Connor McDavid, Legal Sports Betting (Mar. 7, 2022, 1:07 PM), https://bit.ly/3iH6bI3.
 Nat’l Hockey League Players’ Ass’n, Collective Bargaining Agreement Between Nat’l Hockey League & Nat’l Hockey League Players’ Ass’n: Sept. 16, 2012 – Sept. 15, 2022 342 (Feb. 15, 2013), https://bit.ly/3iFzXgq.
 Bryan Armen Graham, The NFL doesn’t want players gambling but is happy to gorge on the proceeds, The Guardian (Mar. 10, 2022, 1:46 PM), https://bit.ly/3DiSKYi (internal citations omitted).
 Chris Murphy, Harrah’s Cherokee Casino appointed as Carolina Panthers official sponsor, SBC Americas (Nov. 6, 2019), https://bit.ly/3wMS2Bp (Carolina Panthers and Harrah’s Cherokee Casino); Tim Daniels, Cowboys Become 1st NFL Team to Have Official Casino Partnership, Bleacher Report (Sept. 6, 2018), https://bit.ly/37YEHvl (Dallas Cowboys and WinStar World Casino); Devin O’Connor, Green Bay Packers Name Oneida Casino Official Gaming Sponsor, Expands Longtime Partnership, Casino.org (Aug. 29, 2019, 8:21 AM), https://bit.ly/3DzQRqx (Green Bay Packers and Oneida Casino); Aaron Wilson, Houston Texans Announce Deal With ‘Official Casino Partner’ Caesars, Sports Illustrated: Texans Daily Fan Nation (Aug. 12, 2021), https://bit.ly/3K61LXv (Houston Texans and Caesars Casino); BetMGM Named First Official Sports Betting Partner of Las Vegas Raiders, Cision PR Newswire (Sept. 17, 2020, 4:10 PM), https://prn.to/3Dpmu62 (Las Vegas Raiders and BetMGM); Devin O’Connor, California Tribe Becomes Official Casino Partner of SoFi Stadium and Los Angeles Rams, Chargers, Casino.org (Dec. 17, 2019, 8:18 AM), https://bit.ly/3DmO43R (Los Angeles Chargers and Pechanga Resort Casino); O’Connor, supra (Los Angeles Rams and Pechanga Resort Casino); Wes Burns, Harrah’s Louisiana: New Orleans Saints and Pelicans Join Forces, Betting USA (Dec. 20, 2018), https://bit.ly/36TrfZd (New Orleans Saints and Harrah’s New Orleans); Giants.com, DraftKings and New York Giants Announce Official, Exclusive Sports Betting Deal, NFL.com (Sept. 16, 2020, 10:00 AM), https://bit.ly/35jrZq2 (New York Giants and DraftKings); Carter Lee, NFL Casino Sponsor List Grows with San Francisco 49ers Deal, Top US Casinos (Sept. 20, 2019, 11:23 AM), https://bit.ly/3NyxvX2 (San Francisco 49ers and Cache Creek Casino); Ceysun Dixon, Seattle Seahawks sign ‘transformative’ casino deal, Sports Pro Media (Nov. 30, 2018), https://bit.ly/3wLUMPr (Seattle Seahawks and Snoqualmi Casino); Titans Announce BetMGM as First Official Sports Betting Partner, NFL.com (Sept. 28, 2020, 9:10 AM), https://bit.ly/3JLppYW (Tennessee Titans and BetMGM); FanDuel Group Brings America’s #1 Sportsbook To Virginia With Multi-Year Partnership With Washington Football Team, Washington Commanders (Jan. 26, 2021, 8:44 AM), https://bit.ly/371J8Fu (Washington Commanders and FanDuel).
 The Baltimore Ravens have partnerships with DraftKings, Ravens Name DraftKings Official Daily Fantasy, Sports Betting and Free-to-Play Partner, NFL.com (Aug. 18, 2021, 7:29 AM), https://bit.ly/3LuiBQ5, Caesars, Baltimore Ravens, Caesars Sportsbook, Horseshoe Baltimore and Ravens Announce Premier Sports Betting Partnership, NFL.com (Sept. 8, 2021, 7:59 AM), https://bit.ly/3iNuUL0, and Horseshoe Baltimore, Baltimore Ravens, supra. The Buffalo Bills have partnerships with Caesars, Bills welcome Caesars Sportsbook as an official mobile sports betting partner, NFL.com (Jan. 15, 2022, 8:00 AM), https://bit.ly/38bcCkK, and FanDuel, Buffalo Bills, Buffalo Bills name FanDuel Group as Official Mobile Sports Betting Partner, NFL.com (Jan. 6, 2022, 2:00 PM), https://bit.ly/3uEzII4. The Chicago Bears have partnerships with BetRivers, Mark Potash, Bears partner with Rivers Casino on sponsorship deal, Chicago Sun Times (June 22, 2021, 9:55 AM), https://bit.ly/3tOR6e0, and Rush Street Interactive, Christina Monroe, The Chicago Bears Partner With Sportsbook Rush Street Interactive, Legal Sports Betting (June 24, 2021, 10:18 AM), https://bit.ly/3wJ3oGA. The Denver Broncos have partnerships with BetMGM, Broncos & BetMGM agree to multi-year sports betting partnership, which includes premium lounge at Empower Field at Mile High, NFL.com (July 9, 2020, 10:34 AM), https://bit.ly/3DnsWdq, Betfred USA, Denver Broncos and Betfred USA Sports announce multi-year partnership ahead of Betfred launching a Colorado presence, NFL.com (June 16, 2020, 11:30 AM), https://bit.ly/3x2J2Zd, and FanDuel, Denver Broncos and FanDuel Group announce multi-year legalized sports betting & daily fantasy partnership, NFL.com (June 15, 2020, 11:30 AM), https://bit.ly/3uGR9b3. The Detroit Lions have partnerships with BetMGM, Lions name BetMGM first official sports betting partner, NFL.com (Sept. 3, 2020, 8:53 AM), https://bit.ly/3DmKuqj, and WynnBET, Bryce Derouin, Detroit Lions, WynnBet Announce Sports Betting Partnership, bookies.com (July 15, 2021), https://bit.ly/3tMSmxX. The Indianapolis Colts have partnerships with Caesars, Colts Communications, Caesars Entertainment Named Sports Betting Partner and Official Casino Partner of the Indianapolis Colts, NFL.com (Sept. 16, 2021, 1:00 PM), https://bit.ly/3uFK76j, and WynnBET, Conor Porter, WynnBET becomes sportsbook partner of Indianapolis Colts, SBC Americas (Sept. 20, 2021), https://bit.ly/3JUVXzO. The New York Jets have partnerships with WynnBET, Jets Team Up with WynnBET for A New Sports Betting Partnership, NFL.com (Sept. 14 ,2021, 8:59 AM), https://bit.ly/3Nyy1UY, and Fubo Sportsbook, Jets Announce Multi-Year Partnership with Fubo Sportsbook, New York Jets (Sept. 8, 2021, 8:45 AM), https://bit.ly/3qHsLF2. The Philadelphia Ravens have partnerships with DraftKings, Eagles make DraftKings team’s official daily fantasy sports partner and official sports betting partner, NFL.com (Oct. 1, 2020, 7:31 AM), https://bit.ly/36VTdn2, Genius Sports Limited, Genius Sports Press, Genius Sports to activate in-stadia sports betting partnerships with Philadelphia Eagles, Genius Sports (Oct. 5, 2021), https://bit.ly/3j2RXBH, Fox Bets, Jill R. Dorson, For Eagles, Count ‘Em: Three Sports Betting Partners Is the Charm, Penn Bets (Mar. 10, 2021), https://bit.ly/3IQXKV4, and UniBet, Dorson, supra. The Pittsburgh Steelers have partnerships with BetMGM, Luka Vasic, Pittsburgh Steelers Sign Sports Betting Deal With BetMGM, Sport Techie (Nov. 25, 2020), https://bit.ly/3NzSx82, and UniBet, Austin Bechtold, Steelers Team with Unibet as Official Sportsbook Partner, SteelersNow (Aug. 14, 2021), https://bit.ly/3qKbnPK.
 Wayne Parry, Pro teams bring betting to the game with stadium sportsbooks, AP News (Feb. 2, 2022), https://bit.ly/3iNpu2C.
 Denver Broncos and Betfred USA Sports announce multi-year partnership ahead of Betfred launching a Colorado presence, NFL.com (June 16, 2020, 11:30 AM), https://bit.ly/3x2J2Zd.
 Nat’l Football League Players’ Ass’n, Collective Bargaining Agreement 340 (2020), https://bit.ly/3LhFi9K.
 Nat’l Football League, Gambling Pol’y for NFL Pers. 1 (2018), https://bit.ly/3tLo0fk.
 Nat’l Football League, Gambling Pol’y for NFL Pers. 2 (2018), https://bit.ly/3tLo0fk.
 Sam Carp, NBA Brings in Bally’s as latest authorised sports betting operator, SportsPro Media (Mar. 5, 2021), https://bit.ly/3NyfVmg.
 Murphy, supra note 24 (Brooklyn Nets and Betway); Murphy, supra note 24 (Chicago Bulls and Betway); Kroenke Sports & Entertainment, supra note 24 (Denver Nuggets and PointsBet); Murphy, supra note 24 (Golden State Warriors and Betway); Murphy, supra note 24 (Los Angeles Clippers and Betway); Memphis Grizzlies, Memphis Grizzlies and FanDuel Group announce strategic sports betting and fantasy sports partnership, NBA.com (Nov. 2, 2020), https://on.nba.com/3uFcOQQ (Memphis Grizzlies and FanDuel); Conor Porter, Betway becomes official gaming partner of Milwaukee Bucks, SBC Americas (Feb. 14, 2022), https://bit.ly/3JRZWgA (Milwaukee Bucks and Betway); Dominic Marius-Markham, Betway and Timberwolves ink sponsorship deal, Gambling Insider (Oct. 25, 2021), https://bit.ly/3ITqA7k (Minnesota Timberwolves and Betway); Thunder Announces Expanded Partnership with Riverwind, Newcastle Gaming Center, NBA.com (Aug. 19, 2010, 11:09 AM), https://on.nba.com/3tOflsu (Oklahoma City Thunder and Riverwind Casino); William Hill And Monumental Sports & Entertainment Form Innovative Partnership And Launch New Era Of Sports Betting, Monumental Sports (Oct. 3, 2019), https://bit.ly/3iOaNMu (Washington Wizards and William Hill).
 The Cleveland Cavaliers have partnerships with Betway, Murphy, supra note 24, and Caesars, Cleveland Cavaliers, Caesars Sportsbook Teas Up with the Cleveland Cavaliers Ahead of Sports Betting’s Launch in Ohio, NBA.com (Feb. 24, 2022), https://on.nba.com/35m27dl. The Detroit Pistons have partnerships with FanDuel, Pistons.com, Detroit Pistons Enter Multi-Year Sports Betting Partnerships With FanDuel Group and DraftKings, NBA.com (Nov. 30, 2020, 10:42 AM), https://on.nba.com/3wNzkd4, DraftKings, Pistons.com, supra, BetRivers, Stan Fox, Detroit Pistons Names BetRivers its Official Sports Betting Partner, Lets Gamble USA (Jan. 26, 2021), https://bit.ly/3DpQiiH, and PointsBet, PointsBet Becomes Proud Sports Betting Partner of Detroit Pistons, Add NBA Legend Rip Hamilton to Team, Cision PR Newswire (Jan. 5, 2021, 10:00 AM), https://prn.to/3wMSXlb. The Indiana Pacers have partnerships with DraftKings, Andrew Cohen, DraftKings Signs Deals With Indiana Pacers, Philadelphia 76ers and Boston Celtics, Sport techie (Feb. 14, 2020), https://bit.ly/3NzLlbJ, and PointsBet, Pacers, PointsBet Announce Multi-Year Partnership, NBA.com (Aug. 4, 2020), https://on.nba.com/3NsIzoK. The New Orleans Pelicans have partnerships with Harrah’s New Orleans, Burns, supra note 35, and BetRivers, Rush Street Interactive’s BetRivers Sportsbook is the Official Partner of the NBA’s New Orleans Pelicans, Cision PR Newswire (Feb. 8, 2022, 8:30 AM), https://prn.to/3Dk65jc. The New York Knicks have partnerships with BetMGM, Dorson, supra note 25, Caesars, Dorson, supra note 25, and DraftKings, Cohen, supra note 25. The Philadelphia 76ers have partnerships with DraftKings, Cohen, supra, Betway, 76ers Name Betway Official Partner in Multi-Year Partnership, NBA.com (Oct. 25, 2021), https://on.nba.com/3DtArQf, BetMGM, Team Announces BetMGM as an Official Sports Betting Partner, NBA.com (Dec. 22, 2020), https://on.nba.com/3wJIsze, and Fox Bet, Andrew Cohen, Philadelphia 76ers and Fox Bet Form Sponsorship Partnership, Sport Techie (Nov. 26, 2019), https://bit.ly/3JT1PJY.
 Wayne Parry, Pro teams bring betting to the game with stadium sportsbooks, AP News (Feb. 2, 2022), https://bit.ly/3JY4sdC.
 Bulls.com, FanDuel Group and United Center Announce Plans to Open In-Area Sportsbook, NBA.com (Jan. 31, 2022), https://on.nba.com/3wN6eKM.
 Cleveland Cavaliers, supra note 44.
 Ben DuBose, In $1.6B deal, DraftKings to partner with Tilman Fertitta, Houston Rockets, USA Today Sports: Rockets Wire (Aug. 9, 2021, 1:25 PM), https://bit.ly/3uEpOG9.
 Otwain Flanders, FanDuel Partners Firm Co-Founded by NBA Star Kevin Durant, Vegas Slots Online (Jan. 18, 2022), https://bit.ly/3Nv2tiU.
 Nat’l Basketball Ass’n, Nat’l Basketball Ass’n Const. & By-Laws 47 (Oct. 2018), https://on.nba.com/3tMrWwx.
 Nat’l Basketball Players’ Ass’n, Collective Bargaining Agreement 117 (Jan. 19, 2017), https://bit.ly/3Dj8sCC.
 See Andrew Cohen, TheScore Becomes Seventh MLB Authorized Gaming Operator, Sport Techie (June 30, 2020), https://bit.ly/37278IA (The MLB has sports betting partnerships with TheScore, DraftKings, FanDuel, BetMGM, Fox Bet, Bet365, and Intralot); Zoe Strozewski, MLB Authorizes Bally’s as a Sports Betting Partner, Sport Techie (Mar. 19, 2021), https://bit.ly/3qKN2tn (MLB also has official betting partnership with Bally’s); Andrew Cohen, Arizona Diamondbacks Partner With Caesars to Open Sportsbook Outside Chase Field, Sport Techie (May 7, 2021) [hereinafter Arizona Diamondbacks], https://bit.ly/3tOEWSg (MLB also has partnership with Caesars).
 Steve Bittenbender, MLB Deal with Betcris is League’s First Wagering Partnership in Latin America, Casino.org (July 20, 2020, 9:10 AM), https://bit.ly/3DlmFPy.
 Arizona Diamondbacks, supra note 52 (Arizona Diamondbacks and Caesars); Jordan Bianchi, Boston Red Sox Announce Partnership with MGM International, Bookies.com (Mar. 11, 2019), https://bit.ly/3wNi1IX (Boston Red Sox and MGM International); Darren Rovell, DraftKings Signs Massive Deal with Cubs, Plans for Wrigleyville Sportsbook, Action Network (Sept. 23, 2021, 1:56 PM), https://bit.ly/3Dnh37F (Chicago Cubs and DraftKings); Ted Orme-Claye, Hard Rock Casino gains exposure via White Sox and ESPN deal, Insider Sport (Aug. 27, 2021), https://bit.ly/3DkoM6n (Chicago White Sox and Hard Rock Casino Northern Indiana); Brian Pempus, WynnBET, Cincinnati Reds Announce Partnership For Online Sports Gambling, Hoosier State Bets (June 16, 2021), https://bit.ly/3Llw4ti (Cincinnati Reds and WynnBETS); Margaret Naczek, Milwaukee Brewers and Potawatomi sign multi-year partnership, Milwaukee Business Journal (Mar. 16, 2022, 10:57 AM), https://bit.ly/3NstZxw (Milwaukee Brewers and Potawatomi Casino); Lou Monaco, BetMGM Announces Partnership with MLB’s Pittsburgh Pirates, Bookies.com (July 15, 2021), https://bit.ly/3Dkp1OP (Pittsburgh Pirates and BetMGM); Ezra Amacher, Circa Resort & Casino partners with San Diego Padres, Gaming America (Mar. 31, 2021), https://bit.ly/3iLG1nK (San Diego Padres and Circa Resort & Casino); Chris Murphy, Multi-Year partnership for Texas Rangers and Choctaw, SBC Americas (June 4, 2019), https://bit.ly/380n9Ps (Texas Rangers and Choctaw Casino & Resorts); BetMGM Partners with Washington Nationals to Debut BetMGM Sports Betting App at Nationals Park, Cision PR Newswire (June 10, 2021, 4:45 PM), https://prn.to/3Dnd1vV (Washington Nationals and BetMGM).
 The Colorado Rockies have partnerships with WynnBET, Chris Murphy, WynnBET becomes official sports betting partner of MLB’s Colorado Rockies, SBC Americas (July 8, 2021), https://bit.ly/3qKxmWG, DraftKings, DraftKings Deepens its Presence in Colorado with New Colorado Rockies Deal and Opening of Sportsbook at Mardi Gras Casino in Black Hawk, DraftKings (Sept. 24, 2020), https://bit.ly/3Ny1RJi, and Betfred Sports, Colorado Rockies and Betfred Sports Sign Multi-Year Marketing Agreement, MLB.com (Mar. 3, 2021), https://atmlb.com/3iP0JTD. The Detroit Tigers have partnerships with PointsBet, Darren Rovell, Tigers Ink Deal With PointsBet, Become First MLB Team to Sign Official Betting Partner, Action Network (Sept. 24, 2021, 4:29 AM), https://bit.ly/3uK243M, BetMGM, Detroit Tigers Announce Sponsorship Agreement with BetMGM in Gaming Category, MGM Resorts International (Mar. 31, 2021), https://bit.ly/3uFkn9Y, FanDuel, Rush, supra note 25, and Motor City Casino, Murphy, supra note 25.
 Mark Saxon, Breaking: MLB Players Coax Three Gambling-Related Concessions From Owners, US Bets (Mar. 15, 2022), https://bit.ly/3uF68Cl.
 Sam Profeta, MLB Players Allowed to Endorse Sportsbooks Per New CBA Agreement, Legal Sports Betting (Mar. 15, 2022, 11:59 AM), https://bit.ly/3iLGwOC.
 Major League Baseball, The Off. Pro. Baseball Rules Book 136 (2021), https://bit.ly/3JNWB1T; see also id. (If a player bets with an illegal bookmaker, the Commissioner will have discretion in determining the penalty, however, if the player operates an illegal book, the penalty will be a minimum one year suspension.); see also Memorandum from Comm’r Robert D. Manfred, Jr. on MLB Pol’y on Sports Betting 2 (Feb. 15, 2019), https://atmlb.com/3uxtNVb (This 2019 memorandum on the MLB’s policy on sports betting states that that MLB players “may not bet on any professional or amateur baseball or softball games…or events,” but players “may place legal bets on sports other than baseball or softball.”)(emphasis added).
 Dan Holmes, PointsBet Named Sports Betting Partner with MLS’s Austin FC, Gaming Today (Sept. 16, 2021), https://bit.ly/3LmTNcz (Austin FC and PointsBet); Colorado Rapids Announce Tipico Sportsbook as the Official Presenting Sponsor of the Club’s 2021 Playoffs Run, Colorado Rapids (Nov. 23, 2021, 6:02 PM), https://bit.ly/3JT5tDv (Colorado Rapids and Tipico); FanDuel Group and D.C. United Announce Exclusive, Long-Term Partnership, Our Sports Central (Oct. 27, 2020), https://bit.ly/35oIkde (DC United and FanDuel); CF Montreal (@cfmontreal), Twitter (Mar. 1, 2021, 9:00 AM), https://bit.ly/3Dj3GFr (CF Montreal and Bet99); New York City FC pens strategic deal with Mohegan Sun, iGB (Mar. 7, 2019), https://bit.ly/3qKgPCo (New York City FC and Mohegan Sun Casino); Philadelphia Union Announce New Partnership With Parx Casino, Philadelphia Union (Aug. 22, 2019, 9:00 AM), https://bit.ly/3qNl545 (Philadelphia Union and Parx Casino); Julie Moraine, Luckii.com Named the Timebrs’ Official Online Gaming Partner, Gambling News (April 16, 2021), https://bit.ly/3uvF7RC (Portland and Luckii.com); Ian Nicholas Quillen, Have Seattle Sounders, Native American Tribe Opened New Door To MLS Sports Betting Partnerships, Forbes (Mar. 23, 2021, 4:00 PM), https://bit.ly/36QYn3P (Seattle Sounders and Emerald Queen Casino).
 Ian Thomas, MLS Opens Jersey Sponsorship Category to Sports Betting Brands, Front Office Sports (June 26, 2019), https://bit.ly/3NpcqOO.
 Quillen, supra note 60.
 Chicago Fire FC becomes first MLS Club to launch gambling awareness sessions, Yogonet Gaming News (April 13, 2021), https://bit.ly/35jRCqK.
 Major League Soccer Players’ Ass’n, Collective Bargaining Agreement Between Major League Soccer & Major League Soccer Players Union: Feb. 1, 2015 – Jan. 31, 2020 60-61 (Feb. 1, 2015), https://bit.ly/35jPi3d.
 Andrew Marquardt, Legalized sports betting in the U.S. doubled in 2021. Here’s why that will continue after ‘the greatest weekend in NFL playoff history.’, Fortune (Jan. 24, 2022, 5:44 PM), https://bit.ly/3iPjyGh (“The market for legalized sports betting in the U.S. exploded in 2021, doubling in size as Americans wagered more than $52.7 billion throughout the year.”).
 Becky Sullivan, NFL receiver Calvin Ridley suspended for 2022 season after gambling on games, NPR (Mar. 7, 2022, 6:27 PM),https://n.pr/3tMDfof.
 Brian Pempus, Opinion: Josh Shaw’s NFL Gambling Suspension Was Too Severe, US Bets (Mar. 31, 2021), https://bit.ly/3wIgXGh.
 Felipe Hernandez suspended for betting on MLS matches, MLS.com (Oct. 8, 2021, 4:00 PM), https://bit.ly/3tNTbXt.
 Tocchet pleads guilty, may avoid jail, ESPN (May 25, 2007), https://es.pn/3wLQHuB (Rick Tocchet, former NHL player and, at the time, assistant coach of the then-Phoenix Coyotes, plead guilty to running a sports gambling ring in 2007. While Tocchet denied ever placing bets on hockey or fixing games, the gambling ring “handled $1.7 million in wagers during a 40-day stretch…and included college football games and the Super Bowl.”).
 Greg Wyshynski & David Purdum, Evander Kane betting allegations; What we know and what we don’t, ESPN (Aug. 2, 2021),https://es.pn/3tKni1X; see id. (Evander Kane has a public history with gambling. In November 2019, a Las Vegas casino brought suit against Kane for failing to pay a $500,000 marker and in January 2021, Kane filed for Chapter 7 bankruptcy, in which he claimed he lost $1.5 million gambling “at casinos and via bookie.”)(internal citations omitted).
 NHL Public Relations, NHL investigation regarding Evander Kane completed, NHL.com (Sept. 22, 2021), https://bit.ly/3JOzp3J.
 Jacob Camenker, List of NFL players suspended for gambling: Calvin Ridley joins Josh Shaw, others busted for betting, Sporting News (Mar. 8, 2022), https://bit.ly/37YAIin (NFL Commissioner Roger Goodell stated that Calvin Ridley’s “actions put the integrity of the game at risk, threatened to damage public confidence in professional football, and potentially undermined the reputations of [his] fellow players throughout the NFL.”).
 Nat’l Basketball Ass’n, Nat’l Basketball Ass’n Const. & By-Laws 47 (Oct. 2018), https://on.nba.com/3tMrWwx.
 Major League Baseball, The Off. Pro. Baseball Rules Book 136 (2021), https://bit.ly/3JNWB1T.
 Evan Macy, More pro athletes are betting on sports, Calvin Ridley is just the first to get caught, Philly Voice (Mar. 8, 2022), https://bit.ly/3DkSIPC.