Gambling in New Jersey

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Uptown section of Atlantic City, showing Showboat and The Taj Mahal casino (which closed in 2016)

Gambling in New Jersey includes casino gambling in Atlantic City, the New Jersey Lottery, horse racing, off-track betting, charity gambling, amusement games, and social gambling. New Jersey's gambling laws are among the least restrictive in the United States; legal, in-state online gambling was instituted in New Jersey in November 2013, and the state is challenging Nevada's grandfathered federal statutory monopoly on legal sports betting.

History[edit]

Early era[edit]

Early New Jersey lottery ticket, used to help finance the construction of Queen's College (now Rutgers University) in New Brunswick.

Gambling has a long legacy in New Jersey, with the state historically being more permissive of gambling than most other states. Until they were banned in 1844, lotteries were common in New Jersey. They were used to help pay for the military during the French and Indian War and American Revolution, and help finance the construction of Queen's College (now Rutgers University) and the College of New Jersey (now Princeton University).[1][2]

Freehold Raceway is the oldest racetrack in the United States, with horse racing having taken place there informally since the 1830s. The Monmouth County Agricultural Society was formed on December 17, 1853, and in 1854 they began holding an annual fair with harness racing at Freehold Raceway[3][4] Monmouth Park Racetrack opened in 1870. In 1894, the New Jersey Legislature banned parimutuel gambling,[5] and in 1897 the voters of New Jersey approved a referendum which amended the state constitution to ban all gambling (or possibly all commercial gambling).[6]

Expansion of gambling[edit]

From 1894 to 1939, all gambling was theoretically outlawed in New Jersey, but enforcement was spotty, and it is not clear whether social gambling was prohibited. Bookmaking, numbers games, and slot machines were common through the state, many churches and other non-profit organizations openly held bingos, and Freehold Raceway operated without interruption.[7] Racetrack gambling was re-legalized in 1939. In 1953, voters approved a referendum to officially allow non-profit organizations to have bingo and raffles. In 1959, amusement games were re-legalized after a 1957 court decision had declared them to be a form of illegal gambling.[8] In 1970, 81.5% of New Jersey voted in favor of a referendum creating the New Jersey Lottery,[1] and in 1975, New Jersey initiated the Pick-It (later renamed the Pick-3), the first legal lottery game in the United States where buyers could pick their own numbers.[9]

In 1974, New Jersey voters voted against legalizing casino gambling statewide, but two years later approved a new referendum which legalized casinos, but restricted them to Atlantic City.[10][11] At that time, Nevada was the only state with legal casino gambling. Resorts Atlantic City was the first casino to open in 1978.[12] As part of the state's budget showdown in 2006, gambling in Atlantic City's casinos and at racetracks in the state were forced to close after it was determined that the official monitors from the New Jersey Casino Control Commission were essential and New Jersey law stated that gambling establishments could not legally operate without state oversight. The closures cost the state an estimated $1.3 million in casino revenues in addition to the loss of state taxes collected on casino employee wages.[13]

Sports betting[edit]

In January 2012, New Jersey Governor Chris Christie signed legislation allowing sports betting in New Jersey after it was approved by a 2-to-1 margin in a voter referendum held in November 2011.[14] The law permits any of the state's 12 casinos and 4 racetracks to offer gambling on professional and college sports, but prohibits them from accepting bets on college events played in New Jersey, or out-of-state games involving New Jersey college teams.[15] The New Jersey Division of Gaming Enforcement subsequently issued regulations for sports betting.[16]

The National Collegiate Athletic Association (NCAA), the National Basketball Association (NBA), the National Football League (NFL), the National Hockey League, and Major League Baseball filed a federal lawsuit against New Jersey to prevent sports betting, based on the Professional and Amateur Sports Protection Act of 1992 which banned sports betting in all but four states.[17] In February 2013, United States District Court judge Michael A. Shipp ruled in favor of the athletic leagues, and barred New Jersey from issuing sports betting licenses. The court ruled that under the Commerce Clause of the United States Constitution, the regulation of gambling and the granting of a grandfather clause to four states is within Congress's power.[18][19] In September 2013, a three-judge panel from the 3rd Circuit Court of Appeals voted 2-1 to uphold Shipp's decision.[20][21] Christie said he will appeal the case to the United States Supreme Court.[22]

Online gambling[edit]

In January 2011, the New Jersey Legislature passed a bill sponsored by Raymond Lesniak to allow online gambling by New Jersey residents over the age of 21.[23][24] Because the state constitution only allows casino gambling in Atlantic City,[25] the legislation specified that the computer servers operating the online gambling websites must be located at licensed casinos in Atlantic City.[23] The Lesniak bill evaded possible federal prohibitions against online gambling by authorizing the Casino Control Commission to create regulations to ensure that the bets were placed from inside New Jersey.[23][26] However, Governor Chris Christie vetoed the legislation because of concerns that "allowing customers to bet through any computer terminal left open the chance of commercial businesses such as nightclubs and cafes becoming gambling hubs around the state", and "the bill further created a legal fiction that a bet placed anywhere in New Jersey counted as an Atlantic City bet."[27]

In December 2011, the United States Justice Department issued a legal opinion that the Federal Wire Act only prohibited online sports betting, and not online casino games.[28] John Wefing, a constitutional scholar at Seton Hall Law School, told a state Assembly committee that he did not believe that a constitutional amendment was needed to authorize online gambling because "any online poker bet would not be completed until a server in Atlantic City accepted the wager,"[29] and "wagers are contracts, and the law recognizes that contracts occur where the final action needed to take place occurs."[30] However, State Senator Jennifer Beck has stated that online gambling cannot be legalized with the approval of New Jersey voters,[31] and several federal courts decisions have said that an online bet occurs in both the location of the website, and the location of the gambler.[32][33]

To address Christie's concerns, new legislation was drafted that prohibits businesses other than Atlantic City casinos from advertising online gambling, or allowing their facilities to be used for online gambling.[34][35] On February 26, 2013, a revised bill permitting Internet gambling was overwhelming approved by the New Jersey Legislature, and then signed into law by Chris Christie.[36] The law legalizes online casino gambling for a 10-year trial period, restricts the operation of the websites to Atlantic City's eleven casinos, and imposes a 15% tax on online gambling revenue, instead of the 8% currently imposed on casinos.[37][clarification needed]

The act requires that the gambler be at least 21 years old and play from a computer in New Jersey. The gambler's location will likely be verified through a global positioning system (GPS), and the bill allows interstate compacts to be signed in future in order to authorize multistate gambling.[37] Comps will be available, but will need to be redeemed by visiting the casino.[38] Macquarie Capital estimates that online gambling will provide Atlantic City's casino with $260 to $400 million in additional revenue per year.[39] The Casino Control Commission will create regulations for online gambling. It is unclear when online gambling licenses will be issued, or if there will be any legal challenges to the new law.[36]

In October 2014, New Jersey state regulators reported revenue of over $100 million since regulation began in November 2013.

Expansion of casino gambling outside Atlantic City[edit]

The proposed New Jersey Casino Expansion Amendment resulted from an agreement among Gov. Chris Christie and Democratic state legislators. State legislators were in deadlock over who would be allowed to own new casinos and tax revenue sharing. The measure does not say where the casinos would be allowed. Location and other matters such as tax rates would be determined by enabling legislation to be passed by the state legislature. A law passed by popular vote in 1976 gives Atlantic City a monopoly on casino gambling in New Jersey.[40][41]

An analysis by Fitch, a credit-rating agency, determined that as many as four of Atlantic City's eight casinos would be bankrupted by expanding casino gambling outside the city. Supporters of gambling in North Jersey say that the measure would help Atlantic City by redirecting as much as $200 million a year in tax revenue to the city. Opponents say that it is unlikely that much revenue would be generated and that it would not make up for the losses due to new competition. In recent years four Atlantic City casinos have closed, causing severe economic problems.[42][43]

Casino gambling[edit]

New Jersey currently has seven casinos, all of which are located in Atlantic City. In 2011, New Jersey's casinos employed approximately 33,000 employees, had 28.5 million visitors, made $3.3 billion in gaming revenue, and paid $278 million in taxes.[44] They are regulated by the New Jersey Casino Control Commission and New Jersey Division of Gaming Enforcement.

Current casinos[edit]

Casino Opening Date Theme Hotel Rooms[45] Section of Atlantic City
Bally's December 29, 1979 Modern 1,749 Midtown
Borgata July 2, 2003 Tuscany 2,767 Marina
Caesars June 26, 1979 Roman Empire 1,141 Midtown
Golden Nugget June 19, 1985 Gold Rush Era 727 Marina
Harrah's November 27, 1980 Marina Waterfront 2,590 Marina
Resorts May 28, 1978 Roaring Twenties 942 Uptown
Tropicana November 26, 1981 Old Havana 2,078 Downbeach
Wild Wild West* July 2, 1997 American Old West N/A (shared with Bally's) Midtown
  • The Wild Wild West Casino is officially part of Bally's, but is often considered by the public to be a separate casino.

Renamed casinos[edit]

Casino Name Change
ACH Casino Resort Renamed The Atlantic Club Casino Hotel
Atlantic City Hilton Renamed ACH Casino Resort
Bally's Grand Renamed The Grand
Brighton Casino Renamed Sands Atlantic City
Del Webb's Claridge Renamed Claridge
Golden Nugget (Original) Renamed Bally's Grand
Harrah's at Trump Plaza Renamed Trump Plaza
Playboy Hotel & Casino Permanent casino license denied; renamed Atlantis Casino
The Grand Renamed the Atlantic City Hilton
Trump's Castle Renamed Trump Marina
Trump Marina Renamed Golden Nugget
Revel Hotel Casino Closed; Renamed TEN

Closed casinos[edit]

Casino Opening Date Closing Date Status of Property
Atlantis Casino April 14, 1981 July 4, 1989 License revoked; later became the Trump World's Fair
Atlantic Club December 12, 1980 January 13, 2014 Building and contents sold to Caesars Entertainment, Inc., slots and tables sold to Tropicana Casino & Resort Atlantic City; currently uninhabited
The Claridge Casino and Hotel July 20, 1981 February 2014 Merged into Bally's, then Sold and Reopened as a non-casino hotel
Revel April 2, 2012 September 1, 2014 Building still standing; currently in redevelopment into TEN
Sands August 31, 1980 November 11, 2006 Building demolished; currently "Atlantic: Wonder Park"
Showboat April 2, 1987 August 31, 2014 Reopened as a non-casino hotel/resort on 7/8/2016
Trump Plaza May 26, 1984 September 16, 2014 Building still standing; currently uninhabited
Trump World's Fair May 15, 1996 October 3, 1999 Building demolished; being redeveloped as BET Investments Boardwalk Development Project
Trump Taj Mahal April 2, 1990 October 10, 2016 Building still standing; Purchased by Hard Rock Hotel & Casino

Cancelled casinos[edit]

Casino Status of property
Camelot Cancelled; currently an empty lot
Dunes Atlantic City Never completed; currently an empty lot
Hard Rock Casino Cancelled; currently an empty lot
Hilton (Original) Casino license denied; current site of Golden Nugget Atlantic City
Le Jardin Cancelled; currently an empty lot
Margaritaville Marina Casino Cancelled; current site of Golden Nugget Atlantic City
Mirage Atlantic City Cancelled; currently an empty lot
MGM Grand Atlantic City Cancelled; currently an empty lot
Penthouse Casino Never completed; current site of Trump Plaza's East Tower
Pinnacle Atlantic City Cancelled; currently an empty lot
Resorts Taj Mahal Cancelled; current site of Taj Mahal
Sahara Atlantic City Cancelled; currently a parking lot

New Jersey Lottery[edit]

New Jersey currently has 7 types of lottery games, which are sold by retailers around the state. The games are overseen by the New Jersey Lottery Commission, and the revenue is used to award prize winners (59%), raise money for education (34%), pay commissions to retailers (6%), and cover lottery administrative cost (1%).[46]

Current games[edit]

Game First Sold Frequency of Drawings
Pick-3 May 22, 1975 Twice daily
Pick-4 June 9, 1977 Twice daily
Cash 5 September 30, 1992 Once daily
Pick-6 May 9, 1980 Monday and Thursday
Mega Millions May 26, 1999 Tuesday and Friday
Powerball January 31, 2010 Wednesday and Saturday
Instant games (scratch-offs) June 17, 1975 Upon purchase

Former games[edit]

Game Started Ended
Lottery (original game) December 16, 1970
5-Digit Daily Game November 29, 1972 January 1, 1976
Lottery Bingo/Super Bingo February 6, 1980 July 29, 1981
Lucky 7 February 3, 1990 March 10, 1990
5-Card Lotto January 11, 1988 September 18, 1990
Lotzee June 14, 1998 September 13, 2003
Monopoly Millionaires' Club October 19, 2014 December 26, 2014

Horse racing & off-track betting[edit]

New Jersey currently has four racetracks and four off-track betting (OTB) halls, all of which are regulated by the New Jersey Racing Commission (an entity of the New Jersey Office of the Attorney General).[47] The state passed a law in 2013 permitting one horse race per year on a New Jersey beach, and Monmouth Park will be conducting a beach race in Atlantic City based on the Palio di Siena.[48][49]

Current racetracks[edit]

Racetrack Opening Date Town
Freehold Raceway 1830s (informally)
1854 (official)
Freehold
Meadowlands Racetrack September 1, 1976 East Rutherford
Monmouth Park Racetrack July 30, 1870 Oceanport

Current off-track betting halls[edit]

OTB Hall Opening Date Town
Favorites at Gloucester Township July 2, 2014 Gloucester Township
Favorites at Toms River April 29, 2008 Toms River
Favorites at Vineland March 30, 2007 Vineland
Favorites at Woodbridge October 17, 2007 Fords
Winners Bayonne July 17, 2012 Bayonne

Former racetracks[edit]

Racetrack Opening Date Closing Date Town
Atlantic City Race Course July 22, 1946 January 16, 2015 Mays Landing
Garden State Park Racetrack July 7, 1942 May 3, 2001 Cherry Hill

Charity, amusement, and social gambling[edit]

New Jersey allows non-profit organizations to run bingos and raffles.

The state of New Jersey allows charity gambling, where non-profit organizations (e.g., churches, fraternal organizations) to run bingos, raffles, casino nights, and armchair races.[50] Amusement parks, carnivals, and boardwalks in shore communities are allowed to have amusement games involving skill or chance (e.g., spinning wheels, skeeball).[51] Charity gambling and amusement games are regulated by the New Jersey Legalized Games of Chance Control Commission.

New Jersey permits social gambling (e.g., workplace football pool, a family poker game) insofar as the organizer of the game is on equal terms with the other participants, and does not take a cut of the gambling proceeds. Furthermore, it is never a criminal offense in New Jersey to be a player in a gambling operation.[52] However, the New Jersey Alcoholic Beverage Commission prohibits bars and other holder of liquor licenses from allowing social gambling.[53]

Illegal gambling[edit]

Each year billions of dollars of illegal gambling takes place in New Jersey.[54] Illegal gambling operations range from employees who make money on office sports betting pools to online poker websites to multimillion-dollar enterprises run by organized criminals.[55][56] Despite the availability of legal gambling in New Jersey, studies have shown that illegal gambling persists because it offers options that are not available legally (e.g., casino gambling outside of Atlantic City), and because some gamblers prefer using a bookmaker whom they personally know.[57] State law does not punish players, but a person operating an illegal gambling enterprise, or possessing equipment or records used for illegal gambling can face up to five years' imprisonment depending on the quantity and size of the bets.[58] However, illegal gambling arrests are rare in New Jersey, and there is presumption of non-incarceration for first-time offenders.[59][60]

Minimum age[edit]

A person must be 21 years of age to gamble at a casino in New Jersey.[61] It is legal for a minor to go to a casino, insofar as they do not gamble, consume alcoholic beverage, or remain on the gambling floor.[62] Underage gambling at a casino is a disorderly persons offense (misdemeanor), punishible by a $500–$1000 fine and a mandatory six-month driver's license suspension, and plea bargaining of underage gambling charges is prohibited.[63] The legal age for other forms of licensed gambling (e.g., lottery, horse race) is 18, but a person under 18 may take part in amusement games where the prize is an item (e.g., a stuffed animal), and not cash.[64] There is no minimum age for social gambling.

See also[edit]

References[edit]

  1. ^ a b "New Jersey lottery turns 40 with record $2.6B in revenue". Inside Jersey (Star-Ledger). November 19, 2010. 
  2. ^ Richard Lehne (December 1988). "A contemporary review of legalized gambling in New Jersey". Rutgers University. [permanent dead link]
  3. ^ Jerry Cheslow (January 26, 1992). "If You're Thinking of Living in Freehold Borough". New York Times. 
  4. ^ Barbara Pepe (2003). Freehold: A Hometown History. Arcadia Publishing. p. 81. 
  5. ^ "History of Monmouth Park". Monmouth Park Racetrack. 
  6. ^ "Proposed Amendments to the Constitution" (PDF). Red Bank Register. September 22, 1897. Archived from the original (PDF) on 2015-09-26. No lottery shall be authorized by the legislature or otherwise in this State, and no ticket in any lottery shall be bought or sold within this State, nor shall pool-selling, 
  7. ^ "Capsule History of Freehold Raceway". Freehold Raceway. 
  8. ^ The Encyclopedia of New Jersey. Rutgers University. 2004. pp. 298–299. 
  9. ^ "'Pick your numbers' game to compete with illegal one" (PDF). Red Bank Register. May 9, 1975. Archived from the original (PDF) on 2016-03-03. 
  10. ^ "Casino gambling defeated by state and county voters" (PDF). Red Bank Register. November 6, 1974. Archived from the original (PDF) on 2013-09-12. 
  11. ^ "Casino gambling ok'd" (PDF). Red Bank Register. November 3, 1976. Archived from the original (PDF) on 2013-09-22. 
  12. ^ "Holiday action: Inside casino" (PDF). Red Bank Register. May 28, 1978. Archived from the original (PDF) on 2013-09-16. 
  13. ^ "New Jersey Casinos Close as Lawmakers Struggle to Reach Budget Deal", Fox News, July 5, 2006.
  14. ^ Sarah Coffey (May 25, 2012). "N.J. Moves Towards Legal Sports Betting This Fall, in Time for NFL Season". National Law Review. 
  15. ^ Stacy Proebstle (May 25, 2012). "Sports Betting Coming to NJ Despite Fed Ban, Christie Says". New Jersey 101.5. 
  16. ^ "N.J. ready to issue sports betting licenses in January". Associated Press. October 15, 2012. 
  17. ^ "4 major pro sports leagues, NCAA sue to stop N.J. from allowing betting". Star-Ledger. August 7, 2012. 
  18. ^ National Collegiate Athletic Association v. Christopher J. Christie, No. 12-4749 (D.N.J. 2013)
  19. ^ Christopher L. Soriano (March 1, 2013). "District Court Upholds PASPA, Enjoins NJ Sports Betting". Duane Morris (professional website). 
  20. ^ National Collegiate Athletic Association v. Governor of the State of New Jersey, No. 13-1713 (3rd Cir. 2013)
  21. ^ "Appeals court upholds ban on sports gambling in New Jersey, says US law trumps state statute". The Washington Post. September 17, 2013. 
  22. ^ Matt Friedman (September 17, 2013). "Christie says N.J. will appeal sports betting case to U.S. Supreme Court". The Star-Ledger. 
  23. ^ a b c "N.J. Senate Bill No. 490 (2010)" (PDF). 
  24. ^ Dan Cypra (January 11, 2011). "Intrastate Internet Gambling Bill Passes New Jersey Legislature". Poker News Daily. 
  25. ^ "New Jersey Constitution, Article IV, Section VII, Paragraph 2D". Archived from the original on 2009-06-30. 
  26. ^ Fleisher, Lisa and Alexandra Berzon (March 4, 2011). "Internet Gambling Vetoed in New Jersey". Wall Street Journal. 
  27. ^ Fletcher, Juliet and Donald Wittkowski (March 3, 2011). "Gov. Chris Christie vetoes online gambling bill, citing constitutional concerns". Press of Atlantic City. 
  28. ^ Edward Wyatt (December 24, 2011). "Ruling by Justice Dept. Opens a Door on Online Gambling". New York Times. 
  29. ^ John Brennan (March 12, 2012). "N.J. Legislature could bypass voters on online poker bill, expert testifies". Bergen Record. 
  30. ^ Derek Harper (July 17, 2012). "Expert tells Assembly committee Internet gambling acceptable under state constitution if servers are in Atlantic City". Press of Atlantic City. 
  31. ^ "Online Gambling Bill Passes New Jersey Senate Committee". Casino Connection Atlantic City. April 6, 2012. 
  32. ^ "State of Missouri v. Coeur D'Alene Tribe, 164 F.3d 1102 (8th Cir., Jan. 6, 1999)". 
  33. ^ "Appeals court upholds Internet gambling ban". NBC News. September 1, 2009. 
  34. ^ "N.J. Assembly Bill No. 2578 (2012)" (PDF). 
  35. ^ John Brennan (December 20, 2012). "N.J. Senate overwhelmingly OKs online casino gambling bill". Bergen Record. 
  36. ^ a b Ryan Hutchins (February 26, 2013). "Gov. Christie signs internet gambling into law". Star Ledger. 
  37. ^ a b Suzette Parmley (February 26, 2013). "Christie signs bill legalizing online gambling". Philadelphia Inquirer. Archived from the original on January 16, 2014. 
  38. ^ "New Jersey Allows Online Betting Tied to Its Casinos such as Caesarscasino in Atlantic City.". New York Times. February 26, 2013. 
  39. ^ Hoa Nguyen and Donald Wittkowski (February 27, 2013). "Christie signs Internet gambling bill after revisions by Legislature". Press of Atlantic City. 
  40. ^ [1]
  41. ^ https://www.bloomberg.com/news/articles/2016-01-11/new-jersey-lawmakers-fail-to-agree-on-casino-expansion-plan
  42. ^ [2]
  43. ^ [3]
  44. ^ "New Jersey Commercial Casinos". American Gaming Association. Archived from the original on 2012-07-04. 
  45. ^ Jeffrey S. Chiesa (November 21, 2012). "DGE Announces 3rd Quarter 2012 Results" (PDF). State of New Jersey. 
  46. ^ "FY 2011 New Jersey Lottery Fiscal Year 2012 Revenue Distribution". New Jersey Lottery. 
  47. ^ "Off Track Wagering". New Jersey Racing Commission. 
  48. ^ "N.J. Assembly Bill No. 4149 (2013)" (PDF). 
  49. ^ John Brennan (September 12, 2013). "American Palio at Atlantic City beaches on verge of being official". Bergen Record. Archived from the original on 2014-07-26. The law authorizes the New Jersey Racing Commission to grant one beach horse racing permit per year. The permit can only be granted to a racetrack licensed by New Jersey, and the races cannot last more than two days. 
  50. ^ "Types of bingos, raffles, casino nights & armchair races". New Jersey Legalized Games of Chance Control Commission. 
  51. ^ "Types of certified games". New Jersey Legalized Games of Chance Control Commission. 
  52. ^ "New Jersey Poker Laws". US Poker Sites. 
  53. ^ "Can bars, restaurants or other licensed establishments run betting pools for sporting events such as the Super Bowl?". New Jersey Division of Alcoholic Beverage Control. 
  54. ^ Ari Weinberg (January 27, 2003). "The Case For Legal Sports Gambling". Forbes. It is estimated that $80 billion to $380 billion in illegal gambling takes place in the United States every years. State-by-state amounts are not available, but it is reasonable to assume that at least $1 billion in illegal gambling takes place every year in New Jersey. 
  55. ^ "New Jersey: South Brunswick: Football Pool". The New York Times. January 11, 2002. 
  56. ^ Rudy Larini (March 25, 2008). "45 arrested in illegal Bergen County gambling ring". Star Ledger. 
  57. ^ Sam Borden (March 29, 2012). "Neighborhood Bookies Putting Lines Online". The New York Times. 
  58. ^ "N.J.S.A. 2C:37-1 to N.J.S.A. 2c:37-9". 
  59. ^ "2011 Uniform Crime Report: State and County Arrest Summary" (PDF). New Jersey State Police. There were 103 gambling arrests in New Jersey in 2011, 40 involving juveniles and 60 involving adults. The report does not break down gambling arrests by type, but most of the juvenile arrests are undoubtably for underage gambling rather than running a illegal gambling enterprise. Of New Jersey's 21 counties, eight had no gambling arrests in 2011. 
  60. ^ Travis Tormey (January 26, 2011). "Degrees of Crimes in New Jersey". Tormey Law Firm. 
  61. ^ "N.J.S.A. 5:12-119". 
  62. ^ Donald Wittkowski (December 21, 2011). "Atlantic City casinos target a new non-gambling market: Children". Press of Atlantic City. 
  63. ^ John Marshall (January 11, 2011). "Underage gambling charges in New Jersey". New Jersey Criminal Defense Law Blog. 
  64. ^ "N.J.S.A. 5:8-59".