MOLAG Files Suit to Stop Missouri from Regulating by Threat Letter and Checklist

Samuel Trapp

Jun 26

3 min read

Missouri Licensing Advocacy Group, Inc. (MoLAG) has filed suit in Cole County challenging the State’s use of threat letters, public advisories, renewal pressure, and liquor-license inspection checklists against Missouri businesses over disputed electronic gaming and amusement machines.

This lawsuit is not about legalizing unlawful gambling. It is about process.

For years, machines have operated in Missouri convenience stores, bars, restaurants, fraternal halls, veterans organizations, and other retail locations. The machines are not all identical. They differ by manufacturer, software, settings, payout structure, player-facing operation, route agreement, location, and actual use. Some may be lawful. Some may not be. But the answer cannot come from a press release or a checkbox.

That is the central problem MOLAG is asking the Court to address.

Attorney General Catherine Hanaway has taken the public position that the gray-market era is over. ATC has tied that posture to liquor-license concerns. Demand letters have gone to businesses. Operators and retailers are being asked to remove machines, surrender information, accept the State’s interpretation, or risk civil litigation, criminal charges, seizure, reputational injury, and licensing consequences.

MOLAG’s position is straightforward: if the State says a specific machine is illegal, then the State should prove it as to that specific machine through lawful process.

Inspect the software. Review the settings. Examine the payout structure. Identify the operator, route, location, and actual use. Do not threaten every business in Missouri by press release and then let a liquor agent check a box as if that settles criminal law.

MOLAG’s lawsuit is different from the Tuners Bar & Grill class action already filed in Cole County. Tuners is a named business seeking class relief focused mainly on Attorney General enforcement. MOLAG is an association case. It represents affected members, including operators, route operators, suppliers, retailer locations, and liquor-license holders, without publicly naming every member and increasing their risk of being targeted.

That distinction matters. Many small businesses do not want their names in a public petition before they know whether they will be raided, charged, inspected, or threatened with liquor-license consequences. MOLAG gives affected businesses a way to organize, support the lawsuit, and seek protection without standing alone.

The lawsuit also names more than the Attorney General. MOLAG’s petition challenges the role of ATC, Christin Templeton, Mark James, DPS, and the State of Missouri. The point is not merely criminal enforcement. The point is licensing pressure. ATC regulates liquor licenses. ATC does not become a gaming commission simply because a disputed machine is inside a licensed premises.

The Missouri House’s own legislative history confirms that this is not a simple checklist issue. In 2025 and 2026, the House passed bills that would have created detailed frameworks for video lottery terminals and electronic gaming machines. Those bills addressed definitions, licensing, central control systems, independent testing, payout standards, age restrictions, enforcement funding, transition rules, and appeal rights.

That history does not prove every machine is lawful. MOLAG does not make that argument. But it does prove the issue is technical, unsettled, and legislative in nature. If existing law already clearly made every disputed machine illegal, there would be no need for repeated attempts to define and regulate them.

The current AG/ATC approach skips that process. It treats unresolved legal and technical questions as already decided. It places small businesses in an impossible position: remove machines now, lose revenue now, risk the liquor license now, accept the State’s interpretation now, or litigate later after the damage is done.

MOLAG asks for a reasonable middle ground:

No agency deference.
No checklist substitute for proof.
No renewal-oath trap.
No liquor-license consequence without machine-specific adjudication.
No use of proposed or failed legislation as though it already became law.
No public targeting of small businesses without lawful process.

Missouri can regulate these machines. Missouri can prohibit them. Missouri can tax them. Missouri can create a video lottery system. But it must do so through law, not threat letters.

MOLAG is represented in the Cole County action by Travis L. Noble, Jr. of Sindel, Sindel & Noble, P.C. Travis Noble is counsel of record and filing attorney for the lawsuit. Legal questions regarding the filing may be directed to counsel of record through the law firm.

Affected businesses can learn more and join MOLAG at MOLAG.org.

These issues are also discussed publicly through Civic Outlaws at civicoutlaws.com/podcast, including recent discussion with Representative Jeff Vernetti regarding Missouri gaming legislation, enforcement pressure, and related topics.