According to a legal opinion requested by a sweepstakes casino operator to distribute to payment processors, “a court having competent jurisdiction, presented with a full record and arguments advanced by qualified counsel” would conclude that online sweeps casino-style games are currently legal in 33 jurisdictions — including California.
The legal opinion, dated April 3, 2025, is a unique element of the footer menu of Spins America. Along with the site’s terms and conditions, sweeps policy, responsible gaming policy, and other links you’re used to seeing on sweeps casinos, there is a link titled “Legal Opinion.”
It directs you to a nearly 24,000-word document detailing the reasons that Spins America is or isn’t operating in each of the 50 states and Washington, D.C. — as of April 3, at least.
“The purpose of this Opinion,” the document reads, “is limited to assisting such third parties in determining whether or not to offer payment processing services to the Developer, and for conducting due diligence to inform their business activities.”
What are the 33 markets?
The jurisdictions where the contracted law firm concluded Spins America’s games “may be offered legally” are:
- Arizona
- Arkansas
- California
- Colorado
- Florida
- Georgia
- Hawaii
- Illinois
- Indiana
- Iowa
- Kansas
- Louisiana
- Maine
- Massachusetts
- Minnesota
- Missouri
- New Hampshire
- New Mexico
- North Carolina
- Oklahoma
- Oregon
- Pennsylvania
- Rhode Island
- South Carolina
- South Dakota
- Texas
- Utah
- Vermont
- Virginia
- Washington, D.C.
- West Virginia
- Wisconsin
- Wyoming
The document, nor Spin America’s terms of service, doesn’t list the states where the sweeps casino is live, so this list is not necessarily saying Spin America is active in these states. The document is also from April, so it does not necessarily reflect Spin America’s current status.
Notable states on that list include Arizona, which sent cease-and-desist letters to Stake.us, High 5 Casino, and Rebet two months after this legal opinion was dated (and also one to Modo.us a couple weeks after the opinion’s date); California, which is currently considering a sweeps gaming ban with Assembly Bill 831; and Louisiana, which sent 42 sweeps operators cease-and-desist letters in June, also two months after this legal opinion is dated.
What about the other markets?
Then, the legal opinion states Spins America is not currently operating in the other 18 states. However, that doesn’t mean the firm necessarily believes sweeps casinos are explicitly illegal in those 18 states.
Rather …
“The Firm could not reach a conclusion as to the legality of the Platform at this time, but expressly reserves the right to reevaluate and revisit the legality of the Platform in these states,” the document reads. “Further, given pending sweepstakes regulations and legislation in a number of states, the environment remains dynamic and this Opinion may be subject to revision based on future development.”
The 18 states are:
- Alabama
- Alaska
- Connecticut
- Delaware
- Idaho
- Kentucky
- Maryland
- Michigan
- Mississippi
- Montana
- Nebraska
- New Jersey
- New York
- North Dakota
- Nevada
- Ohio
- Tennessee
- Washington
Notable states on this list include Connecticut, Montana, New Jersey, and New York, which all passed sweeps gaming bans in 2025 (the opinion specifically noted it would exclude states considering sweeps ban bills at the time); Mississippi and Maryland, which have issued cease-and-desist letters to sweeps operators in 2025; and Ohio, one of two states (along with California) with a sweeps ban bill still on the table in the 2025 legislative session.
Looking closer at Arizona, Louisiana, California
In the Arizona Department of Gaming’s press release announcing its June cease-and-desist letters, it wrote the operators violated the state’s gaming laws dealing with promotion of gambling, illegal control of an enterprise, and money laundering.
And in Louisiana Attorney General Liz Murrill’s opinion supporting her state’s 42 cease-and-desist letters, she wrote sweeps casinos are illegal online gambling sites that “offer real-money payouts, use dual-currency or coin-based systems, or offer material prizes such as gift cards, all under the false appearance of legality and trying to compare themselves with legitimate sweepstakes.”
In the April legal opinion posted on Spins America, the firm postulates that online sweeps casino-style games are legal in Arizona and Louisiana because consideration is not required — meaning players can play for free and can get Sweeps Coins (which can be redeemed for cash) for free via daily login bonuses; alternative methods of entry are “clearly disclosed and easily accessible”; and each player has the same odds of winning, no matter how they obtained their Sweeps Coins.
Clearly, lawmakers and regulatory bodies in Arizona and Louisiana disagreed.
When it comes to California, the law firm focused on whether sweeps gaming falls under the state’s definitions of “gambling” or “lottery” — concluding it doesn’t because no consideration of value is required. Meaning, players can play with Sweeps Coins without ever spending a dollar if they don’t want to.
California gaming tribes believe otherwise (as do other proponents of AB831), asserting the “dual-currency” model of gaming — where players can purchase Gold Coin packages that include free Sweeps Coins — constitutes illegal gambling and also infringes on the tribes’ gaming compacts they’ve negotiated with the state.
What about Ohio?
The opinion does not go into detail about the 18 states where it couldn’t at the time reach a conclusion about legality.
One such state, Ohio, is currently considering a bill — House Bill 298 — that would ban online sweepstakes casinos. However, that bill hasn’t seen any movement since late May.
That could be due to the main component of HB298: Legalizing real-money online casinos. Few gambling industry trends face more current resistance than legalizing real-money iGaming. There hasn’t really been a new iGaming state launch since Connecticut in 2021. (We don’t really count Rhode Island, which launched with just one operator — Bally’s — in 2024.)
Plus, resistance seems especially significant in Ohio.
Derek Longmeier, executive director of the influential Problem Gambling Network of Ohio, is loudly and openly opposed to HB298. And, speaking to reporters at the Ohio State Fair in July, Gov. Mike DeWine expressed his opposition as well.
“I’m not for it,” he said. “Basically to put a casino in everybody’s hands, 24/7, I think is probably not a great idea and I think it will cause more pain and suffering in regards to addiction, as far as gaming addiction, so I’m just not for it.”
