*Madeline Waits
I. Introduction
Do you trust your favorite athletes not to waste your life savings? The sports industry is one of the largest markets in America, and gambling has risen alongside it.[1] While gambling is legal in thirty-nine states, Washington, D.C., and Puerto Rico, the underground illegal gambling market poses issues for the legal gambling market, as well as the sports leagues at the heart of the industry.[2] Athletes, coaches, and other individuals involved in professional sports are prohibited from partaking in gambling related to their own leagues, while collegiate athletes are prohibited from gambling on any sport.[3] However, the illegal gambling market has captured athletes, coaches, and even those with ties to well-known figures in the sports industry, such as the interpreter for three-time Major League Baseball (MLB) MVP Shohei Ohtani.[4] In October of 2025, individuals tied to the National Basketball Association (NBA) were arrested, bringing the illegal gambling market back into the spotlight.[5]
II. The Professional and Amateur Sports Protection Act
In 1992, Congress passed the Professional and Amateur Sports Protection Act (PASPA), otherwise known as the Bradley Act, after Senator and former NBA player Bill Bradley highlighted public concern about states sponsoring lotteries that promoted gambling.[6] Under PASPA, states may not “sponsor, advertise, promote, license, or authorize a lottery, sweepstakes, or other betting, gambling, or wagering scheme. . . in which amateur or professional athletes participate or intend to participate.”[7] In passing PASPA, Congress intended to maintain the integrity of professional and amateur sports leagues by preventing athletes, coaches, and other personnel from throwing or fixing games in favor of their wagers.[8] However, in May 2018, the Supreme Court struck down PASPA in Murphy v. National Collegiate Athletic Association, determining that the act violated the Anti-commandeering clause of the Tenth Amendment by granting the federal government unconstitutional power to order states to take specific actions against sports gambling.[9]
III. Post-PASPA Problems
Illegal gambling has been troubling professional and collegiate sports for many years. One of the earliest and most notorious gambling scandals dates back to the 1980s when Pete Rose, manager of the Cincinnati Reds, was caught placing bets on his own team.[10] Since PASPA was overturned, athletes and coaches have continued to face punishments from their respective leagues for violations of league gambling policies.[11] One of the most recent gambling scandals came from the NBA after multiple arrests were made in connection to an ongoing FBI investigation related to a fixed poker scheme.[12] Among the arrestees were Chauncey Billups, head coach of the Oregon Trail Blazers, and Damon Jones, a former Cleveland Cavaliers and Miami Heat player.[13] Billups and Jones were involved in a fixed poker scheme, overseen by La Cosa Nostra crime families.[14] Billups, Jones, and professional sports figures were used as “[f]ace [c]ards” to entice victims into the fixed card games, where wireless technology ensured that the games would play out against their favor.[15] While victims were aware that they were participating in an illegal game, they were unaware that the games were rigged, and often lost large sums of money.[16] Some of the arrestees were also involved in illegal gambling schemes where they leaked unreleased information about player health or other factors that may impact the outcome of the game.[17] While the illegal gambling schemes have legal consequences for the individuals involved, leagues like the NBA have taken the allegations seriously in order to maintain the integrity of their games for players and audiences.[18]
IV. The Future of Gambling
The NBA’s recent scandal is part of a larger ongoing investigation relating to organized crime families and illegal gambling operations.[19] In the October scandal, players and other involved individuals used unreleased injury reports to give co-conspirators advanced notice of player injuries, allowing them to place early bets based on information that was not accessible to the public.[20] Following the arrests, the NBA issued a statement to all thirty teams indicating that it was reviewing its injury reporting policies, but the NBA has yet to issue a public statement regarding the arrests or scandal.[21] The NBA revised its injury reporting policy in December, requiring teams to submit their final injury reports hours before the game rather than the day before.[22] Although the policy focuses on gambling related to player health, the updated policy reflects affirmative steps being taken to make illegal gambling more difficult.[23] Sports gambling has become an integral part of the consumer experience for sports fans.[24] The repeal of PASPA has encouraged leagues and organizations to increase their own management and regulation of athlete or coach involvement in illegal gambling.[25] As the Super Bowl and March Madness approach, there may be heightened supervision of players and coaches regarding gambling in an effort to maintain the integrity of sports by providing education about illegal gambling and setting boundaries on when gambling is appropriate.[26] PASPA’s repeal has prompted states to develop policies that separate legal from illegal gambling, including implementing age restrictions, as well as determining the legality of gambling in the state.[27]
V. Conclusion
Illegal gambling and its underground, yet continuous role in sports poses a threat to the legal gambling organizations due to ongoing scandals and their impact on the integrity of professional and collegiate sports.[28] However, gambling as a whole has brought a new life to sports leagues, as a new generation of viewers tune in to games to assess their odds of placing a winning bet.[29] As gambling scandals continue to unfold, both professional and collegiate sports leagues are under scrutiny to retain control over their players, coaches, and personnel without harming the thrill many fans find in placing a bet on their favorite teams to win it all.
*Madeline is a second-year student at the University of Baltimore School of Law and a Staff Editor for Law Review. She received a Bachelor of Arts in English from the University of Maryland, College Park. She is a member of the Intellectual Property Law Society and hopes to pursue a career specializing in trademarks or copyright.
[1] Zak Anani, The True Size of the Global Sports Industry, Global Institute of Sport, https://gis.sport/news/the-true-size-of-the-global-sports-industry/ (Dec. 9, 2024); see also Alex Lowell, Gamblization: The Rise of Sports Gambling and the Need to Repeal PASPA, 7 Pace Intell. Prop., Sports & Ent. L.F., 255, 256 (2017). https://globalsportsinsights.com/the-2-65-trillion-question-how-big-is-the-sports-industry/
[2] David Purdum, Suspensions, Arrests and Lifetime Bans: A Timeline of Sports Betting Scandals Since the Repeal of PASPA, ESPN (Oct. 23, 2025, at 20:50 ET), https://www.espn.com/espn/betting/story/_/id/39908218/a-line-sports-gambling-scandals-2018.
[3] Logan Reardon, What Are the Gambling Policies for Each Sports League? Here’s What Players Can and Can’t Bet On, NBC4 Los Angeles (March 27, 2024, at 9:35 AM), https://www.nbclosangeles.com/news/sports/what-are-the-gambling-policies-for-each-sports-league-heres-what-players-can-and-cant-bet-on/3373795/.
[4] Purdum, supra note 2.
[5] David Purdum, Chauncey Billups, Terry Rozier Arrested In Gambling Inquiries, ESPN (Oct. 23, 2025, at 7:47 ET), https://www.espn.com/nba/story/_/id/46695228/sources-terry-rozier-arrested-part-gambling-inquiry.
[6] I. Nelson Rose, Betting on Sports Betting, 18 Gaming L. Rev. & Econ., 953, 953 (2014).
[7] Professional and Amateur Sports Protection Act, 28 U.S.C. § 3702(1).
[8] Matthew D. Mills, The Failure of the Professional and Amateur Sports Protection Act, 16 U. Denv. Sports & Ent. L.J. 215, 216 (2014).
[9] Murphy v. National Collegiate Athletic Association, 584 U.S. 453, 479 (2018); see also Hunter M. Haines, Passing the Ball: The United States Supreme Court Strikes Down PASPA and Throws Sports Gambling Back to State Legislatures, 78 Md. L. Rev. 604, 606 (2019).
[10] Daniel Boswell, The Safest Bet: A Comprehensive Review of the Fall of PASPA and the Rise of Sports Betting, 28 U. Mia. Bus. L. Rev. 115, 116 (2019).
[11] Purdum, supra note 2.
[12] U.S. Att’y’s Off.: E. Dist. of N.Y., 31 Defendants, Including Members and Associates of Organized Crime Families and National Basketball Association Coach Chauncey Billups, Charged in Schemes to Rig Illegal Poker Games, Dep’t of Just.: Press Releases (Oct. 23, 2025), https://www.justice.gov/usao-edny/pr/31-defendants-including-members-and-associates-organized-crime-families-and-national.
[13] Id.
[14] Id.
[15] Indictment at 7, U.S. v. Aiello, No. 25-cr-00314-JMA-CHK (E.D.N.Y. Oct. 9, 2025).
[16] Id. at 3.
[17] Purdum, supra note 5.
[18] Id.
[19] See supra notes 12–13 and accompanying text.
[20] Tania Ganguli, NBA Tweaks Its Rules to Thwart Sports Betting Cheats, The New York Times (Dec. 19, 2025), https://www.nytimes.com/2025/12/19/business/nba-sports-betting-injuries.html.
[21] NBA Gambling Investigation: Latest Statements, Updates, ESPN (Nov. 25, 2025, at 13:00 ET), https://www.espn.com/nba/story/_/id/46710738/nba-gambling-investigation-live-updates-latest-arrests-statements-more.
[22] Id.
[23] Id.
[24] See Lowell, supra note 1 and accompanying text.
[25] David Purdum, Supreme Court Strikes Down Federal Law Prohibiting Sports Gambling, ESPN (May 15, 2018, at 12:25 ET), https://www.espn.com/chalk/story/_/id/23501236/supreme-court-strikes-federal-law-prohibiting-sports-gambling.
[26] Corbin McGuire, As Sports Wagering Grows, NCAA Continues Providing Education, Integrity Services and Research, NCAA (May 16, 2023, at 1:34 PM), https://www.ncaa.org/news/2023/5/16/media-center-as-sports-wagering-grows-ncaa-continues-providing-education-integrity-services-and-research.aspx#:~:text=As%20part%20of%20the%20program,long%2Dterm%20financial%20security.%22.
[27] Sean Gregory, Risks and Rewards of the Supreme Court’s Sports Gambling Decision, TIME (May 17, 2018 at 6:33 ET), https://time.com/5280442/supreme-court-sports-betting-repeal/; see also Jordan Millholland and Leighann Thone, Sports Wagering Laws Passed or Updated in 2021, KLRD, https://klrd.gov/publications/sports-wagering-laws-passed-or-updated-in-2021/ (last visited Jan. 16, 2026).
[28] See Lowell, supra note 1, at 265.
[29] Id. at 267.
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