The Division does not consider California Roulette to be the game of roulette because California Roulette is a banked card game. The game of roulette is specifically prohibited by name as being illegal to deal, play, carry on, open, cause to be opened, or conducted, under California law.

As part of these Tribal-state negotiations, house-banked card games were regulated, but certain games such as craps, roulette, and dice-games based on chance remained prohibited under the state constitution and laws. Essentially, California forbids games where a ball or dice alone determines the outcome.