Stake.us Massachusetts Lawsuit: Arbitration Award Confirmed
A federal judge in Boston on October 16, 2026 confirmed an arbitrator's ruling in the Deleon v. Sweepsteaks Limited lawsuit that the Stake.us arbitration clause binds two Massachusetts players, and refused their request to throw it out. The award decided only that their dispute belongs in arbitration. It did not decide whether Stake.us was lawful in Massachusetts.
The case is Deleon v. Sweepsteaks Limited, No. 1:25-cv-11481, before District Judge Richard G. Stearns in the US District Court for the District of Massachusetts. We have followed it since the players asked the court to vacate the award on August 31. Judge Stearns' six-page memorandum and order, docket entry 41, is on the free public mirror of the docket, and we read it in full.
It settles more than the docket entry suggested. It names the arbitrator, says what the award decided, identifies who filed the motion to confirm, and treats a Stake.us player agreement as an international arbitration agreement under the New York Convention because the operator is a Cyprus company based in Australia.
What did the arbitrator decide?
Not money. The order says the American Arbitration Association award of July 30, 2026 was "in favor of, and limited to, the arbitrability of the parties' dispute over the enforceability of an arbitration clause in a gaming contract."
The sequence, as the order sets it out:
- December 22, 2025 - the players filed a demand for arbitration with the AAA, seeking a "determination of arbitrability, pursuant to the District Court's order and the governing terms and conditions at issue."
- July 30, 2026 - after briefing, Arbitrator Paula M. Bagger issued a "final determination" "that the arbitration agreement was binding."
- August 31, 2026 - the players moved to set that finding aside.
- September 21, 2026 - according to the order, "Stake opposed plaintiffs' motion and cross-moved to confirm the finding."
- October 16, 2026 - Judge Stearns denied the motion to vacate and confirmed the award.
That last point closes a question we left open. Entry 38, filed that afternoon, reached the public docket only as the clerk's label "Miscellaneous Relief", with no filer named, and we declined to say who filed it. The order identifies it as Sweepsteaks Limited's cross-motion to confirm.
The players' underlying argument, set out in a footnote, was that a unilateral modification clause in the Stake.us terms left the contract without consideration and void under Massachusetts law as contrary to public policy. That argument went to the arbitrator, and she ruled against them. It is not a hopeless argument in itself: a month earlier, a different judge in the same court refused to send a Modo.us player to arbitration because that site's right to revise its terms meant they never formed a contract. The difference in Deleon is that the court had already handed the question to the arbitrator.
Why did the judge refuse to vacate the Stake.us award?
The players argued two things, and the judge rejected both.
First, that the court had no power to confirm. Sweepsteaks Limited asked for confirmation under section 9 of the Federal Arbitration Act and under section 207, the provision implementing the New York Convention on foreign arbitral awards. Judge Stearns held the award "falls under the Convention" because the agreement is "between two individuals domiciled in United States and a foreign limited company organized under the laws of Cyprus with its principal place of business in Australia." The order records that the players "do not dispute that the Award meets these requirements." Their objection that the terms are "an unsigned, adhesive form agreement" failed on First Circuit authority that adhesion "does not alone make the document invalid." The judge added that confirmation would succeed under section 9 as well, because clause 26.6 of the terms says disputes "shall be referred to and finally resolved by arbitration."
Second, that the arbitrator "exceeded her powers" under section 10(a)(4) of the Act. The order says the players had "not met the heavy burden required to obtain that relief", and that because the terms "constitute a clear and specific agreement to delegate the authority to determine arbitrability questions to the arbitrator," the court would not hear the arguments it had already sent to arbitration in November 2025.
The sharpest passage is about a choice the players made. The judge's 2025 order had told them that if they wished, their "remedy is to refuse to participate in the [arbitration] proceedings and raise the existence issue at a confirmation of award hearing." The new order says they "instead chose to proceed to arbitration and fully litigate their position, including the argument that the agreement was illusory and illegal, and now, being dissatisfied with the result, seek a second bite at the apple, a treat that this court is not inclined to grant."
Why does the New York Convention apply to Stake.us players?
Because it changes the rules a Stake.us player is fighting under. The statute draws the line in section 202: an agreement "entirely between citizens of the United States" falls outside the Convention unless it has some foreign connection, and a company counts as a US citizen only if it "is incorporated or has its principal place of business in the United States." Sweepsteaks Limited is neither, so the judge treated a Massachusetts player's account terms the same way a court treats a cross-border commercial contract.
Two consequences follow from the statute text:
- More time to enforce. Section 9 allows an application to confirm "within one year after the award is made". Section 207 allows it "within three years" for an award "falling under the Convention".
- A different test. Under section 207 the court "shall confirm the award unless it finds one of the grounds for refusal or deferral of recognition or enforcement of the award specified in the said Convention." The order notes in a footnote that section 208 still lets a party argue the domestic section 10(a)(4) ground alongside it, which is how the players' "exceeded her powers" argument was heard at all.
This is the same statute an Illinois player is relying on from the other side. In Chicago, where Sweepsteaks Limited sued a player to turn an award into a money judgment, the player cross-applied to vacate it on September 7 and asked the court to refuse recognition "under Article V of the New York Convention (9 U.S.C. § 207)". The newest entry on that docket is still a September 11 order on the pending motions, with no public text, so its outcome is not known.
What does the ruling mean for Massachusetts Stake.us players?
Not your account. Stake.us's restricted-states help article, dated July 10, 2026 and re-read on October 17, still lists 22 states the platform cannot accommodate, and Massachusetts is not one of them. This is not a state exit or a payout freeze.
What it changes is how much weight the arbitration clause in your terms now carries. An arbitrator has ruled the Stake.us clause binding on Massachusetts players, and a federal judge has confirmed that ruling. A player who wants a judge to hear an argument that the Stake.us terms are void is now arguing against a confirmed award on exactly that point.
The practical step is the opt-out. The Stake.us clause lets a new player escape arbitration and the class-action waiver only by signed written notice sent within 30 days of creating the account, and most of the category runs the same 30-day window. If you are opening an account this month, that letter is the only point where you choose. If you are already in a dispute, the Deleon order shows that whether you take part in an arbitration can decide what a court will later hear, as a Modo.us player who started his own JAMS arbitration also found, and that is a question for a lawyer before anything is filed.
Our Stake.us review scores the brand lowest on Trust and Safety because of its legal file, and our Sweepsteaks Limited operator profile covers the company. If that file puts you off, our Stake.us alternatives and ranked list of the best sweepstakes casinos are the places to start. The Minnesota federal court went the other way and refused to send players to arbitration at all; Stake.us has appealed, and its Eighth Circuit opening brief argues the arbitrator should decide. For the state-law picture, see whether sweepstakes casinos are legal.
Sources & documents
- Memorandum and Order Confirming Arbitral Award, October 16, 2026 - docket entry 41, 6 pages, downloaded and read in full on October 17, 2026; every quotation from the order and the arbitration dates above come from it
- CourtListener docket entries, Deleon v. Sweepsteaks Limited, D. Mass. 1:25-cv-11481 - entry 41 docket text and the entry list, newest entry October 16, 2026, read October 17, 2026
- CourtListener docket record - judge, filing date and named parties
- Memorandum and Order on Motion to Compel Arbitration, November 20, 2025 - the earlier ruling that sent the case to arbitration
- 9 U.S.C. § 9, § 10, § 202 and § 207 - Federal Arbitration Act text quoted above, read October 17, 2026
- Docket entries, Sweepsteaks Limited d/b/a Stake.us v. Zawadzki, N.D. Ill. 1:26-cv-06840 - newest entry September 11, 2026, re-read October 17, 2026
- CourtListener search for Sweepsteaks Limited dockets - 16 dockets, newest filed July 22, 2026, re-run October 17, 2026
- Stake.us help centre, restricted states on the platform - dated July 10, 2026, re-read October 17, 2026
The arbitrator's award itself, the players' brief and Sweepsteaks Limited's cross-motion are not on the public docket; what we report about them comes from the court's order. We did not put questions to Sweepsteaks Limited or the players' counsel before publishing, and this piece makes no finding about the company beyond what the court decided.
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Sources & documents
- storage.courtlistener.com/recap/gov.uscourts.mad.285111/gov.uscourts.mad.285111.41.0.pdf
- www.courtlistener.com/api/rest/v4/search/?q=docket_id%3A70353080&type=rd&order_by=entry_date_filed+desc
- www.courtlistener.com/api/rest/v4/search/?q=docket_id%3A70353080&type=d
- storage.courtlistener.com/recap/gov.uscourts.mad.285111/gov.uscourts.mad.285111.28.0.pdf
- www.govinfo.gov/content/pkg/USCODE-2023-title9/html/USCODE-2023-title9-chap1-sec9.htm
- www.govinfo.gov/content/pkg/USCODE-2023-title9/html/USCODE-2023-title9-chap1-sec10.htm
- www.govinfo.gov/content/pkg/USCODE-2023-title9/html/USCODE-2023-title9-chap2-sec202.htm
- www.govinfo.gov/content/pkg/USCODE-2023-title9/html/USCODE-2023-title9-chap2-sec207.htm
- www.courtlistener.com/api/rest/v4/search/?q=docket_id%3A73465394&type=rd&order_by=entry_date_filed+desc
- www.courtlistener.com/api/rest/v4/search/?q=caseName%3A%22Sweepsteaks%22&type=d&order_by=dateFiled+desc
- help.stake.us/en/articles/8570633-restricted-states-on-the-platform
Every factual claim in this article maps to one of the sources above - that is the publishing bar, not a goal.
FAQ
Did Stake.us win the arbitration?
On the only question the arbitrator decided, yes. Her July 30, 2026 award found the arbitration agreement binding. The order does not say she ruled on the players' gambling-loss or consumer-protection claims, and nothing in it decides whether Stake.us was operating lawfully in Massachusetts.
Have the Massachusetts players appealed?
No notice of appeal appears on the docket as of October 17, 2026, and the October 16 order is the newest entry.
Is this a class-wide ruling?
No. No class was ever certified, and the award and the order concern the two named players.
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