Michigan / Legal position gauge

Elevated risk

Editorial assessment from Michigan-specific research—not legal approval. Licensed Michigan counsel must review before any deployment decision.

Why this rating?

Michigan’s Penal Code still treats unlicensed prize play as gambling. MCL 750.301 makes it a misdemeanor to accept money on the understanding that something of value will be paid contingent on an event “not known by the parties to be certain.” MCL 750.303(1) separately forbids keeping a game of skill, chance, or mixed skill-and-chance used for gaming for hire, gain, or reward. Lottery is construed broadly to suppress evasions even when an operator tries to subtract an element (Face Trading; PowerPick; People v. McPhee). The amusement and redemption cages are narrow and cash-hostile (§ 750.303(2); § 750.310b). The Michigan Gaming Control Board and Attorney General have closed internet-sweepstakes cafés, treated “skill” cabinets with preset outcomes as chance devices, and sent cease-and-desist letters to unlicensed sweepstakes-casino sites. Unlicensed casino-style operations can be charged as a 10-year felony under the Gaming Control and Revenue Act (MCL 432.218). No reported Michigan appellate decision has tested mandatory pre-reveal with exact monetary disclosure, genuine accept/decline, and no charge on decline. That unused 750.301 timing language keeps the rating below high risk; the anti-evasion lottery cases, cash-barred device exceptions, and current MGCB/AG enforcement keep it out of the moderate band.

This gauge also weighs that we identified no charges and no decided case in Michigan against a game that used a full-pool reveal together with mandatory pre-reveal. Banilla, Torch, and JD Prime used an optional viewer of the next assigned result after money was already on the machine. Café terminals paid first, then revealed. Those fact patterns are not this architecture and do not, by themselves, set the rating.

Scale: High risk → Elevated risk → Moderate risk → Unsettled → Moderately favorable → Favorable → Strong position. These are editorial categories, not probabilities of approval or findings of legality.

Source review date: . Has this exact model been tested? · Counsel checklist · Authorities

NCG GAMESMichigan position brief
Michigan  /  Position brief

When is the event
still unknown to the parties?

MCL 750.301 does not ban every prize transaction. It bans accepting money on the understanding that payment will turn on an event “not known by the parties to be certain.” That is Michigan’s own timing language. The NCG position is that once the exact monetary result is disclosed, the event is known—and a decline moves no money. Michigan courts have not tested that sequence. They have tested pay-then-open pull-tab coupons, lottery-club pooling, video-poker credit machines, and café cabinets that MGCB and the Attorney General treat as chance because the outcome is preset or randomized before the player sees it.

Has this been tested? What remains for Michigan counsel
Working position

This brief analyzes the proposed transaction architecture under current Michigan law. It is not a finding of legality, Michigan Gaming Control Board approval, Lottery authorization, or tribal-compact permission. Authorized channels include Detroit commercial casinos, compact tribal gaming, the state lottery, licensed charitable gaming, pari-mutuel racing, licensed internet gaming and sports betting, and the Penal Code’s narrow amusement, redemption, crane, and occasional-promotional exceptions. Const. 1963, art. IV, § 41 requires statewide and local voter approval for new post-2004 gambling authorizations (except the three Detroit casinos and Indian tribal gaming).

Michigan legal starting point

Chapter 44 of the Penal Code still supplies the default ban. Licensed casino, lottery, bingo, racing, and internet-gaming statutes are exceptions, not a retail cash-device pathway.

MCL 750.301

Payment contingent on an event not known to be certain

It is a misdemeanor to take money or a valuable thing with the understanding that money or a valuable thing will be paid “contingent … upon the happening of any event not known by the parties to be certain.” The Court of Appeals has said the legislative goal is suppression of betting, including private commercial pooling (PowerPick; Nine Money Fall Games). The NCG timing argument lives in that “not known … to be certain” clause.

MCL 750.303 / 750.310b

Devices: skill does not save cash play

§ 750.303(1) reaches a game of skill, chance, or mixed skill-and-chance used for gaming for hire, gain, or reward. The mechanical-amusement exception is a 15-replay, no-cash, no-meter cage (Automatic Music). Redemption games under § 750.310b require player skill, noncash prizes (tight gift-card limits), and $3.75 wholesale caps—and they exclude games in which winning depends primarily on fortuitous circumstances beyond the player’s control.

MCL 750.372; 432.203

Lottery ban and the licensed channels

§ 750.372 forbids setting up a lottery or gift enterprise for money. The only promotional carve-out is activity that is “clearly occasional and ancillary” and is not payment solely for a chance to win (Face Trading). Casino-style play is lawful only under the Gaming Control and Revenue Act, the Lottery Act, the Bingo Act, racing law, tribal compact / IGRA, or later licensed internet and sports-betting acts (MCL 432.203).

Central timing question: At the moment money is accepted for a specific transaction, is payment still contingent on an event the parties do not know to be certain? The NCG position is no—disclosure precedes commitment, and decline is free. Michigan has not held whether that sequence escapes § 750.301, the three-element gaming test in Automatic Music, or the anti-evasion lottery construction in Face Trading and McPhee.

Safeguard 1

Exact cost and result are known before acceptance.

Before the player becomes financially committed to a transaction, the system discloses the exact transaction cost and exact monetary result. Accept processes only those disclosed terms.

Why this matters under Michigan law

§ 750.301 is written as a contingency statute. If both parties already know the monetary result, the strongest NCG argument is that payment is not “contingent … upon … any event not known by the parties to be certain.” That is a textual timing claim, not a “skill game” or “sweepstakes” label.

Contrary authority

Face Trading purchasers paid $1 and then opened a predetermined ticket. PowerPick customers paid into pools whose prize depended on later lottery results. The 2025 AG alert treats cabinets that hide a preset outcome behind a spin as chance devices. Prosecutors will argue casino-style presentation still frames the session as staking credits on unknown future offers.

Implementation risk

Weakening factors: showing cost/result after credits are committed, allowing acceptance before disclosure renders, or mismatch between displayed and settled amounts. Any of those would collapse the only textual distinction from § 750.301’s “not known … to be certain” clause.

MCL 750.301Timing of the uncertain event is critical
Safeguard 2

Viewing the offer does not require payment.

The player may see the disclosed offer—including zero or negative-net outcomes—without paying for that transaction. Declining imposes no charge for that offer.

Why timing of consideration matters

MGCB’s internet-café guide says that if a person must pay for internet access or be present to play a game of chance for a prize, that is consideration and the activity is a lottery, not a sweepstakes. NCG separates inspection from commitment: no consideration moves for a declined offer. That is the factual distinction café raids and Face Trading did not have.

Contrary authority

Prosecutors may argue the player purchased access to a sequence of offers by earlier deposit. Face Trading held that a formal “no purchase necessary” path used five times against millions of paid tickets did not remove consideration. Glover and the Colonial Theatre cases treat promotional “free” chances as consideration when they drive paid play. § 750.372(2) itself excludes “payment of money solely for the chance or opportunity to win a prize.”

Face TradingNo payment on decline
Safeguard 3

Monetary results and reel positions are predetermined.

Monetary outcomes are fixed before acceptance within a finite predetermined pool. Reels, symbols, and entertainment layers cannot modify the disclosed monetary result after acceptance.

Distinction from Michigan authorities

Face Trading Ad-Tabs used a finite winning set inside each deal; predetermination was a fact, not a winning defense. The chance the court identified was which ticket the purchaser selected. NCG’s distinction is not predetermination alone—it is predetermination plus disclosure before financial commitment plus a free decline.

Device and amusement problem

Automatic Music held that a draw-poker cabinet awarding replay credits was a gaming device under § 750.303(1) and failed the 15-replay / no-knockoff-meter exception. § 750.303(3) defines a slot machine as a reel device that may deliver, or entitle a person to, a token, money, or property “as a result of the application of an element of chance.” Casino-style reels plus cash redemption sit in the teeth of that definition even if backend logic is predetermined. The 2024 MGCB statement and 2025 AG alert reject “skill + gift card = legal.”

Redemption path is unavailable

§ 750.310b requires an element of skill on each play, prize based on achieving the object or score, noncash prizes, and $3.75 wholesale limits. It excludes roulette, cards, dice, video poker, a slot machine, or any game in which winning depends primarily on fortuitous circumstances beyond the player’s control. Cash-prize NCG play cannot be forced into that exception.

Automatic MusicMCL 750.310b
Safeguard 4

The player may stop and redeem—including cents.

Eligible remaining credits may be redeemed without further play. Redemption includes fractional dollars; balances are not rounded down to trap value in the machine.

Effect on Michigan analysis

Full redemption supports the argument that only accepted transactions consume value and that the player retains a genuine exit. It may mitigate “trapped balance” or forced-continued-play theories. It does not convert a cash cabinet into a § 750.310b redemption game—that statute’s “redemption” means coupons for merchandise, not cash-out.

Limitation

Redemption does not cure an otherwise unlawful gambling transaction. Peace officers may search alleged gaming houses and seize apparatus, money, and related equipment (MCL 750.308). Premises used as a common gambling house or to hold gaming apparatus are separately criminal (MCL 750.302). MGCB café raids have frozen bank accounts as well as machines.

ILLUSTRATIVE CASH-OUT

$22.00 ticket+$0.67 cents→$0.00 remaining
MCL 750.308Exit rights ≠ legality
Safeguard 5

Software enforces non-bypassable rules.

Mandatory pre-reveal, accept/decline, no post-acceptance RNG, predetermined reels, and redemption rules are architecturally enforced—not merely published as disclaimers.

Why enforcement matters in Michigan

Michigan lottery and device cases turn on actual mechanics and how customers used the system. Face Trading disregarded coupon wrappers and unused free entries. MGCB’s café guide says there is no internet-sweepstakes-café exception. Software enforcement is how a § 750.301 timing distinction can be proved if charges are brought under chapter 44, the Consumer Protection Act, liquor-license gambling-device rules, or MGCRA § 18.

Implementation risks

Alternate clients, debug modes, stale-offer acceptance, or server paths that charge on preview would collapse the “known to the parties” distinction and expose operators to chapter 44 misdemeanors, seizure, MCPA civil penalties, liquor-license discipline, and—if the activity is cast as an unlicensed gambling operation—felony exposure under MCL 432.218 and, for online offerings, MCL 432.313. Casino-style presentation without the enforced accept/decline sequence is the fact pattern Michigan agencies are already treating as illegal gaming.

MCL 432.218Engineering ≠ statutory permission
Required analysis

Has this exact model been tested in Michigan?

We did not identify a reported appellate decision in Michigan directly testing this complete transaction architecture—mandatory pre-reveal, exact monetary disclosure before financial commitment, genuine accept/decline with no charge on decline, no post-acceptance randomness, finite predetermined pool, predetermined reels, software-enforced safeguards, and cent-level redemption.

What Michigan courts and agencies have addressed—and how those systems differ

  • Automatic Music & Vending Corp. v. Liquor Control Comm’n, 426 Mich. 452, 396 N.W.2d 204 (1986) — Binding. Draw-poker cabinet with replay credits held a gaming device under § 750.303(1); the 15-replay amusement exception is constitutional but was not met. Restated the common-law triad: consideration, chance, and prize or reward. Partially analogous on electronic prize cabinets and the narrowness of § 750.303(2). Materially distinguishable because players committed credits before the poker outcome was known; not a pre-reveal accept/decline architecture.
  • FACE Trading, Inc. v. Dep’t of Consumer & Indus. Servs., 270 Mich. App. 653, 717 N.W.2d 377 (2006) — Published. Predetermined pull-tab “Ad-Tabs” with coupons and a “no purchase necessary” path held a lottery under § 750.372; not a § 750.372a game promotion; not “clearly occasional and ancillary” promotional activity. Lottery must be construed to suppress evasions (McPhee). Partially analogous on finite predetermined prize sets and cash instant tickets. Materially distinguishable because consideration occurred before the ticket was opened and there was no accept/decline of a disclosed result.
  • Attorney General v. PowerPick Player’s Club of Mich., LLC, 287 Mich. App. 13, 783 N.W.2d 515 (2010) — Published. Lottery-ticket pooling and promotional drawings held to violate § 750.301 (money accepted contingent on an uncertain event), the lottery statute, and related betting provisions; enjoined as a public nuisance. Partially analogous on § 750.301’s uncertain-event text. Materially distinguishable: customers paid into pools whose prize still depended on later lottery results; not a disclosed-result accept/decline terminal.
  • Henry v. Kuney, 280 Mich. 188, 273 N.W. 442 (1937); Gibson v. Martin, 308 Mich. 178, 13 N.W.2d 252 (1944) — Pinball / bagatelle machines that awarded money or free games by chance held gambling devices. Partially analogous on “element of chance” plus prize. Not applicable as a test of mandatory pre-reveal disclosure.
  • People v. Welch, 269 Mich. 449, 257 N.W. 859 (1934); People v. McPhee, 139 Mich. 687, 103 N.W. 174 (1905) — Beano / suit-club schemes; lottery essentials are consideration, prize, and chance, but “lottery” is generic and must be read to stop evasions. Partially analogous on construction; not applicable to NCG architecture.
  • Waterford Redemption Ctr., LLC v. Gaming Control Bd. Exec. Dir., Nos. 352176 & 352177 (Mich. App. May 27, 2021) (unpub.) — Café / “redemption” operators sought a declaration that their games fit § 750.310b. The Court of Appeals affirmed dismissal; it did not decide the merits of the games. Not applicable as a holding on NCG mechanics; relevant only as a caution that operators could not lock in a friendly declaration against MGCB and the Attorney General.
  • MGCB Internet Sweepstakes Café guide; 2012 café raids; 2024 skill-game statement; 2024–2025 online sweepstakes cease-and-desist letters; AG Nessel Feb. 5, 2025 consumer alert — Agency and enforcement materials, not judicial tests of NCG architecture. They show how Michigan currently treats pay-for-access cafés, hidden-preset “skill” cabinets, and sweepstakes-branded casinos.

Enforcement and regulatory activity (not judicial approval)

In 2012, MSP, MGCB, and the Attorney General raided sweepstakes cafés and reported closing dozens of locations that sold internet time paired with casino-style entries. MGCB’s current café guide states there is no internet-sweepstakes-café exception. In 2024 MGCB publicly rejected the claim that skill plus gift cards legalizes slot-like cabinets. In 2024–2025 it issued cease-and-desist letters to unlicensed online operators including sweepstakes-branded sites (Stake.us, VGW, and later a nine-site wave). The Attorney General’s 2025 alert tells consumers that “skill” machines with preset outcomes or RNGs are games of chance. We did not identify an Attorney General opinion approving mandatory pre-reveal, accept/decline, cash-redemption terminals. Absence of a decision testing this complete architecture is not a judicial determination of legality.

Critical distinction

“No reported Michigan decision directly testing this architecture” is materially different from “A Michigan court has ruled this architecture legal.” Neither statement has been found true here. Face Trading is the closest published analogue on predetermined finite pools—and it is adverse on payment-before-reveal. PowerPick is the closest published analogue on § 750.301’s uncertain-event text—and the event there was still unknown when money was taken.

No direct Michigan appellate precedent identified
Strongest contrary arguments

What Michigan prosecutors and regulators could argue.

1. Anti-evasion lottery construction

McPhee and Face Trading instruct courts not to let an operator subtract one formal element and escape the popular meaning of “lottery.” Counsel should expect that argument to be applied to “the result was predetermined” and “the player could decline.”

2. Chance as to which offer appears next

Even if each accepted transaction’s result is fixed and shown, prosecutors may locate chance in the draw from the finite pool—the same move Face Trading made when the winning set was predetermined but the purchaser did not know which ticket was selected. The 2025 AG alert already describes hidden presets as chance.

3. § 750.303 does not require a chance-only game

Keeping a game of skill or mixed skill-and-chance used for gaming for hire is independently forbidden. A “no chance / disclosed result” label can be recast as still maintaining a game for gain. Automatic Music did not need a predominance holding to condemn a credit-awarding cabinet.

4. Amusement and redemption exceptions are cash-hostile

§ 750.303(2) is a 15-replay mechanical cage. § 750.310b forbids cash, caps prizes at $3.75 wholesale, and excludes slot-like fortuity. MGCB’s 2024 statement: gift cards do not legalize a chance cabinet. Do not market NCG as a redemption or skill game.

5. Felony overlay if cast as an unlicensed gambling operation

Conducting a gambling operation without an MGCB license is a felony punishable by up to 10 years and $100,000 (MCL 432.218). Offering internet gaming without an internet-gaming-operator license is a separate felony (MCL 432.313). Chapter 44 gambling offenses are also racketeering predicates (MCL 750.159g). Café investigations have used asset freezes, not just machine seizures.

6. Session-wide staking and credit balances

Money inserted upfront creates a continuing credit balance. Each Accept may be characterized as risking that balance across a session—the structure café and Ad-Tab cases treated as paying for chances, not inspecting disclosed sales.

7. Article IV, § 41 and licensed-channel politics

New legislative authorization of gambling after January 1, 2004, generally needs statewide and local voter approval. Even a clever Penal Code theory does not create a fourth Detroit casino or a retail slot franchise. Compact tribes, the Lottery, and licensed commercial casinos have institutional reasons to treat slot-like cabinets as encroachment regardless of backend logic.

NCG factual responses and residual risk

Responses: at acceptance the monetary result is fixed and known to both parties; declines cost nothing; no post-acceptance RNG; Face Trading and café cases involved payment-before-outcome mechanics; the amusement and redemption exceptions are not the NCG theory—the timing of § 750.301’s “not known … to be certain” clause is. Residual risk: published anti-evasion lottery authority, an element-of-chance device line, cash-barred exceptions, felony MGCRA/internet-gaming overlays, and an aggressive MGCB/AG remain material pending Michigan counsel review. The timing distinction is supportable; it is not settled.

Face TradingAdverse authority must be addressed, not dismissed
Complete transaction analysis

Chronology: when is the player financially committed?

“The player accepts or declines a fully disclosed, predetermined transaction. No later random event alters the monetary result. The legal question is whether Michigan treats that sequence as accepting money contingent on an event not known by the parties to be certain under MCL 750.301—or as something materially different from the pay-then-open tickets in Face Trading and the still-unresolved pools in PowerPick.”

This is the position to test—not a Michigan legal conclusion. Compare to Face Trading (pay $1, then open a predetermined ticket) and PowerPick (pay into a pool; prize still depended on a later uncertain lottery event).

  1. 1 / POOLFinite pool predetermined
  2. 2 / REQUESTPlayer requests next offer
  3. 3 / REVEALExact result disclosed
  4. 4 / TERMSCost and result both known
  5. 5 / CHOICEAccept or decline
  6. 6 / SETTLENo post-accept RNG
  7. 7 / EXITRedeem remaining cents
Authorities

Primary Michigan sources.

Verified . Binding precedent and statutes distinguished from unpublished decisions, Attorney General opinions, and executive guidance.

  1. [1]
    Michigan statute · uncertain-event wagering

    MCL 750.301 ↗

    Accepting money or a valuable thing with the understanding that payment will be contingent on a race, contest, game, or “any event not known by the parties to be certain.” Misdemeanor: up to 1 year or $1,000. Official legislature text; numbering unchanged from the 1931 Penal Code (amended 2002 PA 672).

  2. [2]
    Michigan statute · devices

    MCL 750.303 ↗

    Keeping a game of skill, chance, or mixed skill-and-chance used for gaming for hire, gain, or reward. Subsection (2): 15-replay mechanical amusement cage. Subsection (3): slot-machine definition (reel + element of chance + token/money/property) and 25-year antique exception. Official legislature text.

  3. [3]
    Michigan Supreme Court · binding

    Automatic Music & Vending Corp. v. Liquor Control Comm’n, 426 Mich. 452 ↗

    396 N.W.2d 204 (1986). Draw-poker replay cabinet is a § 750.303(1) gaming device; 15-replay exception constitutional but unmet. Common-law gaming: consideration, chance, and prize or reward.

  4. [4]
    Michigan Court of Appeals · published

    FACE Trading, Inc. v. Dep’t of Consumer & Indus. Servs., 270 Mich. App. 653 ↗

    717 N.W.2d 377 (2006). Predetermined Ad-Tab cash tickets held a lottery; unused free path did not negate consideration; promotional exception requires activity that is clearly occasional and ancillary. Official construction of MCL 750.372 / 750.372a.

  5. [5]
    Michigan Court of Appeals · published

    Attorney General v. PowerPick Player’s Club of Mich., LLC, 287 Mich. App. 13 ↗

    783 N.W.2d 515 (2010). Lottery-club pooling violated MCL 750.301 and lottery/betting statutes; public-nuisance injunction. Leading application of the “uncertain event” text to a commercial prize scheme.

  6. [6]
    Michigan statute · redemption games

    MCL 750.310b ↗

    Chapter 44 inapplicable to a redemption game only if skill determines the outcome, prizes follow score/object, awards are noncash (tight gift-card rules), and wholesale/redemption caps are met. Excludes games in which winning depends primarily on fortuitous circumstances beyond the player’s control.

  7. [7]
    Michigan statute · lotteries

    MCL 750.372 ↗

    Ban on setting up a lottery or gift enterprise for money. Subsection (2): promotional activity that is clearly occasional and ancillary; excludes payment solely for a chance to win or purchase of a product for substantially more than fair market value. Misdemeanor: up to 2 years or $1,000.

  8. [8]
    Michigan Supreme Court · binding

    People v. McPhee, 139 Mich. 687 ↗

    103 N.W. 174 (1905). “Lottery” is generic and must be construed to remedy the mischief and suppress evasions. Quoted and applied in Face Trading and PowerPick. See also People v. Welch, 269 Mich. 449 (1934) (consideration, prize, chance).

  9. [9]
    Michigan statute · authorized casino gaming

    MCL 432.203 ↗

    Gaming Control and Revenue Act (1996 IL 1 / Proposal E). Casino gaming authorized only as conducted under the act. Saves racing, the state lottery, bingo/millionaire parties, tribal/IGRA gaming, and specified Penal Code recreational and promotional exceptions (including §§ 750.310b and 750.372).

  10. [10]
    Michigan statute · unlicensed operation felony

    MCL 432.218 ↗

    Conducting a gambling operation without a board license: felony, up to 10 years or $100,000, or both, plus license bar. The charging overlay MGCB cites against unlicensed casino-style businesses.

  11. [11]
    Michigan Supreme Court · binding

    Henry v. Kuney, 280 Mich. 188 ↗

    273 N.W. 442 (1937). A machine is a gambling device where an element of chance lets the player win or lose money, trade checks, or prizes. Followed in Gibson v. Martin, 308 Mich. 178 (1944). Device-line “element of chance” test—not a predominance statute.

  12. [12]
    Michigan Constitution · lotteries

    Const. 1963, art. IV, § 41 ↗

    Legislature may authorize lotteries. After January 1, 2004, a law authorizing any form of gambling—and new lottery table or player-operated device games—needs statewide and local voter approval, except the three Detroit casinos and Indian tribal gaming. Official legislature text (2004 Proposal 04-1).

  13. [13]
    Michigan statute · search and seizure

    MCL 750.308 ↗

    Warrant to search an alleged gaming house or lottery premises; seizure of apparatus, money, and related equipment; arrest of keepers and persons found there. Disposition of seized articles: § 750.308a.

  14. [14]
    Michigan statute · gambling house / apparatus

    MCL 750.302 ↗

    Keeping or occupying a common gambling house, or permitting gaming apparatus on the premises. Misdemeanor: up to 1 year or $1,000. Manufacturer out-of-state / licensed-establishment exception in subsection (2).

  15. [15]
    Michigan statute · internet gaming

    MCL 432.313 ↗

    Lawful Internet Gaming Act. Offering internet gaming for play in Michigan if not an internet gaming operator is a felony (up to 10 years / $100,000). “Internet game” is defined in MCL 432.303 as a skill-or-chance game offered through the internet in which a person wagers money for the opportunity to win money. Definitions: MCL 432.303.

  16. [16]
    MGCB · enforcement guidance

    MGCB, Internet Sweepstakes Cafés guide ↗

    No café exception to MCL 750.301 / 750.372. Paying for internet access or being required to be present to play for a prize is consideration. Promotional exception is occasional and ancillary only (Face Trading). Agency guidance, not a judicial holding. See also the 2012 café raid release and the MGCB illegal-gaming bulletin.

  17. [17]
    Attorney General / MGCB · current enforcement

    AG Nessel, illegal gaming-machine alert (Feb. 5, 2025) ↗

    Consumer alert: “skill” cabinets with preset outcomes or RNGs are games of chance; cash, gift cards, or other prizes do not legalize them. Related: MGCB July 16, 2024 skill-game statement; Feb. 12, 2025 online-casino C&Ds. Enforcement messaging, not holdings.

  18. [18]
    Michigan Court of Appeals · unpublished

    Waterford Redemption Ctr., Nos. 352176 & 352177 ↗

    (Mich. App. May 27, 2021) (unpub.). Affirmed dismissal of café operators’ bid for a declaration that their games were § 750.310b redemption games. No merits holding on the machines. Not precedent under MCR 7.215(C).

Disclaimer: This brief is research and issue-spotting for professional discussion—not legal advice, Michigan Gaming Control Board approval, Lottery authorization, tribal-compact permission, or permission to operate. No Michigan Attorney General opinion specifically addressing mandatory pre-reveal NCG architecture was identified. Waterford Redemption Center is unpublished. Attorney General alerts and MGCB guides are not judicial holdings. House skill-game proposals pending in 2025–2026 are not current law. Michigan counsel should verify all citations, effective dates, local enforcement practices, compact and lottery exclusivity questions, and the actual deployed software before any compliance representation.