Prior to the Supreme Court of the United States’ landmark decision in Murphy v. NCAA, there was little oversight of unusual wagering activity on a national scale.

On October 23, 2025, the sports world was shocked with the announcement that multiple NBA figures were arrested by the FBI and subsequently indicted on charges related to gambling. The two notable figures arrested were Chauncey Billups, head coach of the Portland Trailblazers, and Terry Rozier, point guard for the Miami Heat, while another individual arrested was Damon Jones, a former NBA player. The sports media and anti-gaming advocates were quick to react, pointing to sports-betting companies and the proliferation of the industry in the United States as culprits. However, such instant reactions seem to assume the criminal conduct never occurred prior to the legalization of sports betting. Instead, the arrests arguably demonstrate that the strict regulation of the sports-betting industry is effective.

Rozier’s Gambling Is Flagged on March 23, 2023

On March 23, 2023, the Charlotte Hornets were slated to play the New Orleans Pelicans. Rozier was a point guard for the Hornets, averaging 21 points per game and 35 minutes per game, and he had started in all 63 games he played that season. However, on that game day, Rozier suffered an apparent foot injury after scoring 5 points and playing 10 minutes.

Prior to the game, sports-betting monitor U.S. Integrity notified sportsbooks that an unusual uptick of wagers were placed on Rozier. In total, $263,000 was bet on Rozier that day. Sportsbooks immediately flagged the activity and notified the NBA of the coincidental influx of these bets.

The NBA conducted its investigation into the unusual amount of wagers on aspects of the game. However, the NBA ultimately cleared Rozier of any wrongdoing. Rozier returned to play the next season and was traded to the Miami Heat in January 2024.

Over two years following the suspicious betting activity on Rozier, the FBI arrested Rozier for his alleged involvement in a scheme where he shared information regarding his foot injury and how he would leave the March 23, 2023, game early.

The Finger Is Pointed at Sportsbooks

Responding to the scrutiny, the NBA stated:

While the unusual betting on Terry Rozier’s "unders" in the March 2023 game was detected in real time because the bets were placed legally, we believe there is more that can be done from a legal/regulatory perspective to protect the integrity of the NBA and our affiliated leagues.

The NBA explained that individual player proposition bets deserve heightened security because of sports betting’s popularity.

However, the conduct of sportsbooks and independent observers tells a different story. On March 23, 2023, prior to the game subject of the FBI’s investigation, sportsbooks and the independent sports-betting monitors noticed and flagged the influx of bets. Sportsbooks are required by law to develop robust internal controls concerning the integrity of sporting events.

For example, the Massachusetts Gaming Commission mandates, pursuant to 205 CMR § 238.18(d), that licensed sportsbooks report:

(d) Any information relating to the following, which shall also be reported to the relevant Sports Governing Body:

1. Abnormal betting activity or patterns that may indicate a concern with the integrity of a Sporting Event;

2. Any potential breach of the internal rules and codes of conduct pertaining to Sports Wagering of a relevant Sports Governing Body;

3. Any other conduct that corrupts a betting outcome of a Sporting Event for purposes of financial gain including, but not limited to, match-fixing;

4. Suspicious or illegal Wagering activities, including, but not limited to, use of funds derived from illegal activity, Wagers to conceal or launder funds derived from illegal activity, use of agents to place Wagers, and use of a false identification;

5. Complaints of an athlete engaging in prohibited wagering conduct.

Other states have similar laws requiring sportsbooks to maintain internal monitoring systems for detecting and reporting irregularities to state gaming regulatory authorities.

The Rozier situation is strong evidence that the gambling regulations are in fact working. On the day the alleged improper bets took place, sportsbooks flagged the unusual wagering activity and reported it to the NBA and, presumably, state gaming regulators. Such conduct underscores the fact that even as sports gambling permeates America, licensed sportsbooks are abiding by the rules and protections prescribed by state regulators.

Prior to the Supreme Court of the United States’ landmark decision in Murphy v. NCAA, there was little oversight of unusual wagering activity on a national scale. The only state to offer regulated sports wagering prior to Murphy was Nevada. Now, 39 states and the District of Columbia regulate sports wagering (including Missouri, which is due to launch this year). Each state provides its own unique set regulations, but all generally maintain mandatory reporting requirements pertaining to suspicious wagering activity and obligations to assist law enforcement investigations.

Rozier’s arrest is arguably a win for the $14 billion-dollar industry. It demonstrates that the system works in detecting and reporting unusual activity and the cooperative nature of regulators and law enforcement authorities overseeing the industry. There is no guarantee that Rozier’s arrest would have happened prior to 2018, but the arrest is another piece of concrete evidence demonstrating regulated sports wagering is protected from criminal influences.

Although criminal actors will continue to find ways to try and subvert systems for their own improper gain, sportsbooks frequently show their ability to be the vanguard in protecting the integrity of the sports betting marketplace by identifying and flagging improper betting behavior by athletes since the expansion of sports betting.[1] Their assistance, along with independent watchdogs, was instrumental in unearthing the alleged improper conduct in the NBA.

For More Information

If you have any questions about this Alert, please contact Frank A. DiGiacomo, James A. Lewis, Niko Gounaris, any of the attorneys in our Gaming Industry Group or the attorney in the firm with whom you are regularly in contact.

Notes

Disclaimer: This Alert has been prepared and published for informational purposes only and is not offered, nor should be construed, as legal advice. For more information, please see the firm's full disclaimer.