Note About Hamiltonian Structure of Non-Linear Massive Gravity
  We perform the Hamiltonian analysis of non-linear massive gravity action studied recently in arXiv:1106.3344 [hep-th]. We show that the Hamiltonian constraint is the second class constraint. As a result the theory possesses an odd number of the second class constraints and hence all non physical degrees of freedom cannot be eliminated. 
J. Kluson
hep-th gr-qc