Muhammad Ali Act: Applies Only to Boxers?

In discussion with various individuals in the mixed martial arts industry, it is often said that while mixed martial artists should be afforded some form of protection, the Muhammad Ali Act is not applicable to mixed martial arts.  In support of this notion, it is said that the Muhammad Ali Act utilizes the terms “boxer” and “boxing,” and makes no mention of the terms “mixed martial arts” or “mixed martial artist.”

 

This article argues that despite the usage of the term “boxer,” the Muhammad Ali Act is still applicable to mixed martial arts and mixed martial artists.  To make this argument, an analysis of the history behind the Interstate Land Sales Full Disclosure Act (the “Land Sales Act“) and its applicability to condominium sales is instructive.  As discussed below, the federal agency designated to administer the Land Sales Act determined that it applied to condominiums nine years before Congress used the term “condominium” at all. 

 

I.  Land Sales Act.1

 

A.  Scope and Protections of the Land Sales Act.

 

The Land Sales act was enacted by Congress to combat fraud in the sale of land.  The Land Sales Act was the federal government’s response to widespread fraud occurring in the interstate sale of lands.  The use of mails for interstate land sales proliferated during the 1960’s, and abuses soon became widespread.2 In general, these sales involved undeveloped realty, such as swampland in Florida, desert in Arizona, land under water or otherwise undevelopable.

 

The Land Sales Act, in summary, prohibits a “developer” from selling or leasing any “lot” in a “subdivision”, through the use of interstate commerce unless it complies with the Land Sales Act or falls within an applicable exemption.  Like the securities laws after which it was modeled, the Land Sales Act uses disclosure as it primary tool to combat fraud.

 

B.  Legislative History of the Land Sales Act.

 

As initially enacted by Congress, the Land Sales Act did not use the word “condominium” at all.  Many legal commentators and scholars believed the Land Sales Act did not apply to condominiums by intention of Congress and for policy reasons.  In drafting the statute to protect purchasers of land, Congress made the Land Sale Act applicable to “lots.”  Commentators presumed that Congressional usage of the term “lot” without inclusion of “condominium” supported the interpretation that the Land Sales Act applied only to raw land.

 

The Office of Interstate Land Sales Registration (”OILSR“), however, created by the Housing and Urban Development (”HUD“) agency to oversee the Land Sales Act, determined as early as 1969 that the Land Sales Act applied to condominiums.  Again, in 1972, OILSR issued an “advisory opinion which concluded that condominium units were included within the definition of ‘lots.’”3 OILSR subsequently formalized this interpretation of the Land Sales Act in the form of regulations.  According to the OILSR, a condominium is equivalent to a subdivision, with each condominium unit being a “lot.”

 

HUD issued a formal pronouncement in 1973, declaring that it interpreted the Land Sales Act to apply to condominiums, and stated that it consistently followed the same interpretation since 1969.  HUD reiterated the position of the OILSR in determining that the Land Sales Act applied to condominiums again in 1974.  In 1978, Congress amended the Land Sales Act, and for the first time, included the word “condominium” into a single provision.  Congress inserted the word “condominium” in a provision exempting sales of improved land under certain circumstances.  In enacting this amendment to the Land Sales Act, Congress again created fodder for debate.  One view interpreted this amendment as necessarily implying that the Land Sales Act was applicable to condominiums–otherwise, the inclusion of the term “condominium” in the exemption provision would be rendered superfluous.  The second view, however, imparted a much narrower intent on behalf of Congress in passing the amendment.  According to the second view, the amendment acted only to exempt land sales upon which a “condominium” rests.  This view is also supported by rules of statutory construction, which mandates that where Congress employs a term in one section of a statute, and not in another, the term should not be implied where it was excluded. 4

 

C.  Judicial Interpretation of the Land Sales Act.

 

In 1985, the United States Court of Appeals for the 11th Circuit definitively ruled that the Land Sales Act applied to condominiums.5 In deference to the agency interpretation of HUD, and in implementing the antifraud and consumer protection purposes of the Land Sales Act, the court ruled that the Land Sales Act applied to condominiums.  The court, in reaching its conclusion, not only looked toward HUD’s interpretation of the Land Sales Act, but also towards the legislative history and purposes behind passage of the Land Sales Act.  The court noted that the legislative history of the Land Sales Act employs the terms “land” and “real estate,” in addition to the term “lots.” Thus, Congressional intent to prevent fraud in the sale of real estate, regardless of the form of ownership, should control.  In ruling that the Land Sales Act applied to condominiums, the court concluded that the fraudulent sale of land is “not rendered any less fraudulent if the condominium form of ownership is utilized.”6

 

II.  Imparting the Lessons of the Land Sales Act to the Muhammad Ali (Safety) Act.


The Land Sales Act was enacted to protect consumers in the purchase of “lots” from unscrupulous developers and promoters.  Despite the usage by Congress of the term “lots”, with no mention of the term “condominium”, HUD examined the legislative history and intent, and determined that the consumer protections and antifraud purposes behind the Land Sales Act applied equally to both raw land and condominium units.  Judicial interpretations of the Land Sales Act echoed HUD’s interpretation, even despite contrary evidence of Congressional intent.

 

Unlike the sale of interstate lands, there is no federal agency designated to oversee activities in boxing or mixed martial arts, despite prior legislative attempts.  Thus, no federal agency is available to issue agency interpretations applying the Muhammad Ali Act to boxers and mixed martial artists.  However, many members of the media and state athletic commissions have declared that the protections afforded by the Muhammad Ali Act to boxers are equally necessary for mixed martial artists.  Mark Cuban has stated publicly he believes the Muhammad Ali Act already applies to mixed martial arts.  Armando Garcia, commissioner of the California State Athletic Commission, believes similar protections should be afforded to mixed martial artists.  Fighters themselves believe the Muhammad Ali Act should apply to mixed martial artists, including, among others, Matt Lindland and Randy Couture.

 

Additionally, like the Land Sales Act, the legislative history of the Muhammad Ali Act indicates that Congress employed the terms “fighter” and “athlete” in addition to the term “boxer.”  Finally, the Congressional intent in passing the Muhammad Ali Act, namely, the protection of boxers from exploitive and coercive business practices, applies with equal force to the current status of mixed martial artists.  Thus, despite the Muhammad Ali Act’s usage of only the term “boxer,” as the history behind the interpretation and development of the Land Sales Act instructs, do not assume necessarily that the Muhammad Ali Act does not apply to mixed martial artists.

 

For a more expanded article on the Muhammad Ali Act’s applicability to mixed martial arts, please click here.

 

Rob Maysey is a licensed attorney in the states of Arizona, California, and Minnesota. He received his BA in Politics from Whitman College and his JD from Cornell Law School. He has followed the sport of mixed martial arts closely since being introduced to Brazilian jiu-jitsu in 1998 by a law school classmate.

 


[1] 15 U.S.C.A. § 1701-1720.

[2] Olivier, James L.  “Beyond Consumer Protection:  The Application of the Interstate Land Sales Full Disclosure Act to Condominium Sales,” University of Florida Law Review , 37 UFLLR 945 (1985).

[3] Id. At 951.

[4] Id. at 953.

[5] Winter v. Hollingsworth Properties, Inc., 777 F.2d 1444 (11th Cir. 1985).

[6] Id. at 1448.

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    Consulting with a healthcare skilled or experienced fitness advisor is crucial to find out the appropriate dosage, cycle length, and monitoring protocols primarily based
    on private goals and total health. Anavar is popular among bodybuilders and athletes because it could help enhance strength, improve lean muscle mass,
    and cut back fat.

    References:

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  9. best steroid on the market

    It is simple to see why gym rats are popping var tablets like they’re sweet since anavar has the power to each develop muscle and decrease physique fat, whereas also
    having minimal negative effects. As A Outcome Of it’s regarded to be a relatively innocent chemical, anavar is quite
    well-liked among bodybuilders. Although there are a number of adverse effects, the majority of them
    can usually be avoided because the substance in question is neither very potent nor harmful.

    Gynecomastia stays attainable on HGH as a end result of elevation of progesterone (13).
    HGH just isn’t going to trigger as a lot cardiovascular threat in comparison with steroids, because it
    doesn’t trigger vital fluctuations in LDL/HDL scores (12).
    Nevertheless, in our experience, these results are
    typical when combining HGH and insulin collectively.
    Otherwise, stick along with your AAS plan for now, and I’ll bet there’s a lot more you could get out
    of your steroid cycles when you wait until you’re in a position to do HGH the right
    way. HGH is now not the area of the most advanced and hardcore bodybuilders.
    Real, pure-quality HGH cannot be produced in underground labs because
    of the huge costs and complexity. However, many Chinese labs look
    like manufacturing high-quality HGH, which is offered as generic.

    Shopping For from such labs is a big gamble; you’ll need to know the supply before handing over cash.

    When stacked with Anavar, it can assist to amplify the muscle-building and
    fat-burning effects of both compounds. This stack isn’t beneficial for beginners,
    as Trenbolone is a highly poisonous injectable
    steroid. Your muscle gains using HGH will heavily
    rely upon which (if any) anabolic steroids you stack it with, as this is the commonest strategy.
    HGH will compound upon the anabolic and muscle-building results of steroids.
    Using a robust bulking steroid with HGH may see you gaining 10-20lbs of muscle
    in a normal cycle. Somatotropin is a human growth hormone used to deal with some medical situations, and additionally it
    is popular with bodybuilders.
    For an anabolic steroid, Anavar produces some first rate results with the chances of suffering from
    any of the negative unwanted facet effects being pretty low.
    In truth, this is such a gentle anabolic steroid that females
    are able to tolerate it with out going by way of any of the
    side effects. When DHT’s are used, they’ll cause the prostate to enlarge or trigger points on this area.
    Sadly, in terms of prostate enlargement, there’s a double-edged sword.
    That is that DHT and estrogen are both factors in relation to
    prostate enlargement and points. DHT is a potent inhibitor of
    estrogen, and estrogen can additionally be a problem.
    So that signifies that too high a DHT level will cause prostate
    enlargement over time, and likewise too low.

    Trenbolone can be a versatile compound, being utilized
    as a chopping or bulking steroid. But before you jump on the bandwagon, there are
    a quantity of things you have to know. From dosage tips to the length
    of the cycle, we’ll explore all of the essential particulars that can help you make an knowledgeable choice.
    So, get able to take your health journey to the next level with an Anavar
    cycle for males.
    There have been no dosage directions specific to ladies when Anavar was first released.
    The solely caution was that pregnant girls ought to chorus from using the drug.
    Beginner bodybuilders in search of to add a modest
    quantity of muscle regularly use it because of its
    much less toxic nature. Alternatively, they might decide to stack the above steroids in conjunction with Anavar.

    Some bodybuilders could find that Anavar dosage of 50mg
    per day is too little, so one thing like 80mg each day could also be extra appropriate.
    Nevertheless, I would always suggest that you don’t bounce straight to higher doses.
    Some folks could possibly see decent outcomes on 50mg a day eight weeks cycle.

    Albuterol is run by way of the same method as clenbuterol (in capsule form).
    Nevertheless, in drugs, albuterol is prescribed
    within the type of an emergency inhaler. Dr. Thomas O’Connor additionally
    has anecdotal evidence of clenbuterol contributing to
    heart charges of 180 beats per minute. Pumps can also turn out to be bigger because of superior blood
    circulation to the muscles. Clenbuterol stimulates the central nervous
    system (CNS), thus growing adrenaline output and elevating the body’s temperature by as much as 1 degree.
    Clenbuterol is an effective anti-asthma medicine, having been an accredited prescription drug for humans since 1977 in a quantity of countries
    (albeit not the US). Nonetheless I didn’t wish to take
    an opportunity and go along with my original plan so now the first day of week 2 I added 100mg check base, just
    pinned a.
    Anavar is able to avoid this by shifting water from outside the muscle cell, to the inside.
    This is considered one of the greatest compounds you probably can take to preserve your muscle tissue while you’re on a cutting phase.
    Slicing steroids even have the facility to extend muscle development,
    even when consuming fewer energy.

    References:

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  10. anabolic steroids street names

    This makes Testo-Max a perfect alternative in your risky Testosterone Propionate.
    When used at moderate doses and for limited cycle lengths, Testosterone Propionate mustn’t
    trigger the overwhelming majority of customers critical cardiovascular issues.
    Stacking it with more cardiovascular-stressing steroids will undoubtedly raise the danger.

    These are prime circumstances for your physique to have a more
    durable time filtrating the blood and hunk in your body.
    Less filtration and less optimum performance of these organs mean extra salt remains in the blood, which in flip will result
    in water retention. If you experience nausea whereas
    taking Anavar, it is necessary to discuss to your physician.
    They may find a way to prescribe a different treatment that does not trigger this facet impact.
    Additionally, Anavar also helps to extend your vitality ranges, making it easier to stay lively and burn off even more calories.

    For males, Anavar can cause enlarged breast tissue, painful erections, and
    lowered fertility. Nonetheless, legal guidelines can differ by
    nation, so it’s all the time a good idea to examine the current
    legal guidelines in your nation or state. All The Time seek the
    assistance of with a healthcare provider before starting any new medicine or complement.

    Understanding these basic variations is essential in selecting the
    steroid that aligns finest with individual objectives
    and preferences. When considering the use of any
    anabolic steroid, it’s important to listen to potential
    side effects and risks. Dianabol carries a better risk of
    estrogenic side effects as a end result of its conversion to estrogen in the
    physique.
    Most notably, there is a danger of liver problems, together with liver
    tumors and cysts. It’s at all times critical to
    contemplate the pros and cons before considering
    taking this artificial steroid, understanding and acknowledging the risks coming
    with the obvious advantages. Whereas Anavar may have its potential makes use of, careful consideration and session must be
    a high precedence. This guide will stroll you through every little thing you have to find out about Anavar, from its uses to the potential unwanted side effects.
    Whether Or Not you’re considering using anabolic steroids for medical causes or health objectives, being
    informed may help you make higher choices. Anavar (oxandrolone) is a
    well-liked anabolic steroid used by many individuals for various causes.
    Whereas it’s typically praised for its muscle-building benefits, figuring out the way
    it works can help individuals avoid the risks concerned with its use.

    He’s been educating people for 7 years via his articles, written after studying science papers,
    professional books and consulting high medical doctors within the
    field. It also has awesome fats burning and muscle-sparing attributes, leaves you looking dry and FULL.
    Usually when slicing, your muscles can turn into depleted, particularly when using
    diuretics…but this won’t occur with anavar. One of the potential side effects of Anavar is
    bloating and water retention. This may be brought
    on by the strain that Anavar can placed on the liver and kidneys.

    500mg weekly of Testosterone Propionate, with Dianabol at 25mg every day for ten weeks and Deca for
    the primary 4 weeks solely at 400mg weekly, is an efficient intermediate
    cycle. Side effects should still be manageable at
    this level, although nearer attention will need to be paid to cholesterol and blood stress ranges.

    At this stage, you’ll nearly certainly be taking a look at stacking, which permits you
    to keep Testosterone Propionate at lower doses. Increased
    purple blood cell manufacturing carries extra oxygen to the blood and muscle tissue.

    When mixed with extra protein synthesis, you will see a sooner recovery
    process post-intensive train.
    It’s a dry steroid which implies you won’t have any water
    retention, identical as with Tbol. In short, Anavar is
    sweet water retention, it won’t make you look bulky or your muscles
    seem too smooth or blurry, on the similar time, you’ll look exhausting, full and powerful.
    Water retention could be a common problem for bodybuilders,
    and it can be attributable to a wide selection of factors such as food
    regimen, medication, and hormones. Whereas water retention may
    not all the time be harmful, it might possibly sometimes intervene with bodybuilding goals
    such as gaining muscle definition and losing body fat.
    Fortunately, there are several strategies that can assist bodybuilders scale back water retention. Anavar 10mg is usually used in doses
    of mg day by day for men, whereas girls typically
    stick with lower doses, ranging from 5-20 mg daily.
    It’s really helpful to run Anavar 10mg
    for 6-8 weeks cycles, relying on individual goals and tolerance.

    Nevertheless, its higher androgenic score suggests a larger potential for
    androgenic unwanted side effects like zits, hair loss,
    and elevated physique hair. In contrast, Anavar possesses a decrease anabolic rating but notably decrease androgenic effects, presenting itself as a milder possibility regarding potential androgenic unwanted effects.
    The completely different anabolic and androgenic
    properties of Dianabol and Anavar must be taken into account when choosing a steroid that
    suits individual tolerance and desired outcomes.
    Yes, one of many massive advantages of HGH is that
    girls can use it without the virilization that
    comes with using anabolic steroids.
    When you’ve got misplaced weight as a outcome of these circumstances, Anavar can effectively allow you to regain it.

    For those excited about Anavar 10mg, our other products,
    corresponding to Trenbolone and Primobolan, can also be priceless additions to your cycle.

    These compounds assist users optimize results relying on whether they concentrate on muscle achieve, cutting, or total performance enhancement.

    Once More, this comes right down to value and the ability to source LEGITIMATE or
    top-quality generic HGH kits (of which there are very few).

    In Any Other Case, stick along with your AAS plan for now, and I’ll wager there’s much
    more you will get out of your steroid cycles when you wait until you’re ready to do HGH the best method.
    To use HGH primarily for muscle development functions, you’ll desire a naked minimal of 12 weeks.

    Everybody is completely different, and your present well being standing, age,
    and other factors will make your experience different from that of the following person.

    References:

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