John Doe vs. Richard Roe – 3 F.J. 197 (October 29, 2011) – Fantasy Football Collusion

SUPREME COURT OF FANTASY JUDGMENT

John Doe vs. Richard Roe

ON PETITION FOR WRIT OF CERTIORARI FROM AN ANONYMOUS FANTASY FOOTBALL LEAGUE

Decided October 29, 2011

Cite as 3 F.J. 197 (October 2011)

Factual Background

An anonymous fantasy football league (hereinafter referred to as “the league”) has been in existence since 2009 and is comprised of twelve (12) teams.  These teams compete against each other on a weekly basis during the National Football League (“NFL”) season using the statistics of professional players as a basis for accumulating points in head-to-head competition with opponents to determine which fantasy team won or lost.  The league is a keeper league where each team is permitted to retain one player from their current roster.  The parties did not disclose the specifics of the league’s scoring system except to say they utilize a standard scoring format.  For the purposes of this analysis, the Court will presume the standard scoring system in place has the following values: 6 points for a rushing or receiving touchdown, 4 points for a passing touchdown, 1 point per 10 yards rushing or receiving, 1 point per 25 yards passing, 2 extra points for touchdowns over 40 yards, and minus 2 points for fumbles lost and interceptions.  It is unknown whether the league is governed by a written Constitution.  

Prior to Week 5 of the NFL season, a trade was made between John Doe and Richard Roe.  The trade consisted of John Doe sending Eli Manning (QB-NYG) to Richard Roe in exchange for Joe Flacco (QB-BAL). Both teams used their acquired player to start in lieu of their regular quarterback’s bye week.  

On October 26, 2011, Doe and Roe made another trade by swapping Manning and Flacco again and returning them to their original owners. Several league members have voiced their opinions that this sort of activity is unethical and is a form of collusion.

Procedural History

The Court is not aware of what the league’s trade approval process is.  However, based on the case submission, it appears that the second trade did go through and its validity is now being challenged.  There are no rules in place which restrict or prohibit such actions as trading players back and forth between teams.

Issue Presented

(1)   Should there be any restrictions or time limitations placed on the ability to trade back players who have previously been traded for each other already?

Decision

The Supreme Court of Fantasy Judgment typically favors individual fantasy sports participants and teams’ ability to make moves, transactions, and trades.  People pay money to purchase a team in a league and have an expectation of freedom to draft and manage their team accordingly.  See 4 Ponies v. Carson City Cocks, 3 F.J. 13 (May 2011).  Whether success is bred from that individual’s decision-making is purely left to some skill, luck, dedication, and savviness.  The Court recognizes that this is not a normal trade evaluation because the question is whether trading back players already traded for each other should be allowed and whether it could be construed as a form of collusion. 

The scope of the Court’s authority is to govern and advise when there is a dispute as to the validity of trades, rulings, decisions or other issues that arise within the league.  See Silveramo v. Nation, 2 F.J. 38, 41 (October 2010) (holding that making a judgment on whether an individual did something stupid falls outside of the Court’s jurisdiction).  It is not up to the Court to make a determination on what is considered intelligent.  Unwise decisions should not be scrutinized or vetoed merely because they are unwise.  See Road Runners v. Urban Achievers, 3 F.J. 47, 50 (June 2011) (holding that the main criteria for evaluating a trade is its inherent fairness, not whether it was an intelligent decision by a league member to make the deal).  Rather, the Court’s role in this jurisdiction is to evaluate the objective merits of a deal and ensure that the integrity of the league is maintained.  See Victoria’s Secret v. C-Train, 2 F.J. 32, 35 (October 2010). 

The Court has always held that the approval or rejection of a trade is based purely on its fairness, free from collusion, and in the best interests of the league.  Whether a trade is intelligent or popular will not be part of the analysis.  See 4 Ponies v. Beaver Hunters, 3 F.J. 26, 27 (June 2011).  The virtue of a trade is measured in both quantifiable criteria and subjective needs of the teams involved.  See Carson City Cocks v. Stud Muffins, 3 F.J. 23, 24 (May 2011).

Before getting to the central issue of the case, the Court would be remiss if it didn’t address the actual value of the trade itself.  Based on their statistical performances thus far in 2011, Eli Manning is having a better year than Joe Flacco.  Manning has amassed 103 points according to ESPN’s standard fantasy football scoring whereas Flacco only has 77.  However, the differential between their passing yards and touchdowns is hardly consequential enough to conclude that there is a disparate value.  On its face, trading Manning for Flacco is a trade that would be approved by the Court in a vacuum and free of these ancillary issues.  

When doing a trade analysis, the Court always first analyzes whether there is any collusion or under-the-table dealings going on between teams involves.  This goes right to the heart of the issue at hand.  First and foremost, there is an unwritten and generally accepted code of conduct within the fantasy sports industry that is premised on good faith and fair dealings within leagues and amongst league members. See Going, Going, Gonzalez v. Fantasy Baseball League, 1 F.J. 29, 30 (May 2010).  Unfortunately, this case is ripe with accusations of collusion and unethical conduct between two teams. 

When presented with allegations or suspicions of collusion, the Court will look at the evidence in the light most favorable to the accused(s).  This is because acts of collusion within a fantasy league are one of the most serious fantasy sports crimes that can be committed and can undermine the integrity of a league more so than almost anything else.  See Team Zero v. Samcro Reaper Crew, 3 F.J. 177, 179 (October 2011).  Here, the two teams involved in the trade are lumped together as the alleged offending parties because the allegations are made jointly against both Joe Doe and Richard Roe.

The Court was not presented with the teams’ rosters.  Based on the case submission, it appears to be undisputed that both Doe and Roe had other quarterbacks on their rosters that they chose to start over Manning and Flacco.  The initial deal appeared to have been made with the intention to supply each other with a viable quarterback option during the other team’s quarterback bye week.  Even if true, that in itself is not demonstrative of collusion.  Fantasy football team owners do not need to justify their motivations for building their roster as they see fit so long as it comports with the league rules and requirements.  There are a myriad of reasons why people make roster decisions such as accumulating depth, compensating for injuries, and filling in for bye weeks. See Silveramo v. Nation, 2 F.J. 38, 40 (October 2010).

The alleged offense now comes when the two teams trade back the players to their original teams giving the impression that it was a mutual loan.  The teams in the league that oppose such actions argue that this type of activity is an unethical way to circumvent roster requirements and results in an unfair advantage with respect to waivers and the order of priority.  On the contrary, Doe and Roe argue that they did not violate any rules of the league with making these trades.  They also argue that it was not etched in stone that they would trade back with each other depending on the players’ performances and health status.  Further, Richard Roe argues that he had acquired Ahmad Bradshaw (RB-NYG) in a trade after the initial deal involving Manning and Flacco.  Roe testified that he was hesitant to have so many Giants at premium positions, which was a major factor in his decision to trade Manning back to Doe.

When looking at the totality of the circumstances and the nature of the trades that were made, the evidence does show that, more likely than not, there was malicious intent that rises to the level of collusion.  Outside of written proof or verbal confirmation, there is no way to definitely prove the existence of such conduct.  Regardless, the Court can draw inferences from the evidence presented and the circumstances surrounding the proposed trade whether collusive conduct is present.  See Tiger’s Blood v. Hulkamaniacs, 3 F.J. 58, 61 (July 2011).

While Roe makes some valid arguments justifying his actions, it does not change the fact that there appeared to be an agreement of some sort in place between the teams.  Without a confession or some form of written proof, the Court will rely on circumstantial evidence and weight the totality of the circumstances.  When doing so, the Court concludes that there was some form of tacit agreement between John Doe and Richard Roe with respect to their two trades for the same players.  There can be no other conclusion reached when trying to analyze the motivations for trading backup quarterbacks to each other, and then returning them merely three weeks later.  As stated previously, the trades themselves are fair and equitable as Manning and Flacco present reasonable value for each other.  Manning is clearly better and has more value, but Flacco is equitable compensation for him.  However, when two teams in the league manipulate the system like this, it cannot be overlooked no matter how mundane the consequences are.  

The trades themselves should not be undone or overturned.  However, it is critical for the league to establish and implement new rules to prevent and discourage such behavior.  Some suggestions for rules include: 1) once players have been traded between teams, they cannot be exchanged for each other by the same teams at any point; or 2) use the terms of proposal #1 but put time limitations on how long teams must wait to trade players back to their original teams.  The Court defers to the league commissioner to decide the best course of action for the league, but it is plainly clear that some action is required to prevent such behavior in the future. 

It cannot be stressed enough how serious an issue it is to allow teams to make individual agreements with each other to circumvent the rules for personal benefit.  While some valid justifications were made by the breaching parties, the facts and circumstances lead the Court to conclude that some form of collusion existed between Doe and Roe.  While the infraction and net result was minor, it still must be adjudicated with force.  However, because there were no rules in place which prevented such activity, there can be no penalties enforced against Doe and Roe.  Without an enforceable written rule in a league constitution, the league commissioner must use his discretion in determining how to handle a particular issue.  The best course of action is to establish new guidelines for such activity and discourage any collusive endeavors between league members.  There is nothing that undermines the integrity of a fantasy league more than collusive conduct between teams.  The Court holds that the trades between Doe and Roe should be upheld, but their conduct itself was collusive in nature and new rules should be created going forward.  The Court recommends prohibiting trade-backs altogether to avoid any allegations of impropriety.

IT IS SO ORDERED.

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