The Steel Curtain vs. Rusty Trombones – 3 F.J. 201 (November 2, 2011) – fantasy football collusion

SUPREME COURT OF FANTASY JUDGMENT

The Steel Curtain vs. Rusty Trombones 

ON PETITION FOR WRIT OF CERTIORARI FROM THE DAY TRADERS FANTASY FOOTBALL LEAGUE

Decided November 2, 2011

Cite as 3 F.J. 201 (November 2011)

Factual Background

The Day Traders Fantasy Football League (hereinafter referred to as the “DTFFL”) has been in existence since 2007 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 DTFFL is a non-keeper league where each team drafts from scratch each season.  The DTFFL is hosted on ESPN’s platform and utilizes its standard scoring system with 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. 

The DTFFL is governed by a written constitution which provides the rules and guidelines for the league.  Each team received a copy of the constitution prior to the league’s draft.  With respect to the rules on trading players between teams, the constitution provides the following pertinent language:

ARTICLE VI – TRADES

  1. Teams are permitted to trade players with each other so long as the trades are fair in value and there is no collusion involved.
  2. The commissioner shall have the authority to approve or reject all trades.  There will be no league vote or veto process.

The DTFFL also utilizes a waiver list to determine the order and priority for adding free agents during the season.  Once a team successfully acquires a free agent, that team is automatically sent to the bottom of the waiver order.  This is standard procedure for ESPN’s platform.

On November 1, 2011, the Steel Curtain acquired free agent Jackie Battle (RB-KC) through the league’s waiver wire.  They had the #1 position on the waiver list at the time and were able to acquire whichever free agent they desired.

On November 2, 2011, the Steel Curtain traded Battleto the Rusty Trombones in exchange for Brandon Lloyd (WR-STL).  At that time, the Rusty Trombones were 10th in the waiver priority order and had no chance of acquiringBattle via free agency.

The DTFFL commissioner suspects that there was an agreement in place between the Steel Curtain and the Rusty Trombones with respect to the acquisition of Jackie Battle and the immediate trade the day after.  It is alleged that the Rusty Trombones knew they would not have the opportunity to acquire Battlebeing 10th on the waiver list, so they offered the Steel Curtain a trade if they would selectBattle as a free agent acquisition to immediately deal to them. 

Procedural History

Using the authority he was granted in Article VI., Section 2 of the DTFFL Constitution, the commissioner rejected this trade on the basis of suspicions of collusion.  Both the Steel Curtain and Rusty Trombones challenged the commissioner’s decision arguing that these transactions were not collusion.  The commissioner refused to change his decision, so the Steel Curtain and Rusty Trombones submitted this case to the Court seeking an opinion on whether their actions constituted collusion, and thus, permitting their trade.

Issue Presented

(1)   Is an agreement between teams to utilize one team’s beneficial waiver position solely for the purpose of adding a player and immediately trading him to the other team considered collusion?

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 case is not a typical trade dispute.  Rather, it is a question of whether two teams’ conduct in manipulating the waiver order constitutes collusion.  This is significant because the commissioner has conceded to the Court that the trade itself of Jackie Battle in exchange for Brandon Lloyd was fair and would have been approved if not for the suspected collusion.  The Court agrees that this trade, in a vacuum, should be approved.

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).  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.  See 4 Ponies v. Beaver Hunters, 3 F.J. 26, 27 (June 2011). 

Outside of financial theft or monetary deceit, there is no more serious allegation in fantasy sports than collusion.  Nothing undermines the integrity of a fantasy league more than collusive conduct.  See Team Zero v. Samcro Reaper Crew, 3 F.J. 177, 179 (October 2011).  This is because 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 John Doe v. Richard Roe, 3 F.J. 197, 199 (October 2011); Going, Going, Gonzalez v. Fantasy Baseball League, 1 F.J. 29, 30 (May 2010).  When the sanctity of a fantasy league is tarnished with skepticism and speculation over everyone else’s intentions, the fun and competitiveness come to a screeching halt and the league’s fate is usually impending doom.

When presented with allegations or suspicions of collusion, the Court will look at the evidence in the light most favorable to the accused(s).  See Doe v. Roe, 3 F.J. at 199.  This is because allegations of collusion are extremely serious and have such significant repercussions on everyone involved in the league.  Here, the two teams involved in the trade are lumped together as the alleged offending parties because the allegations are made jointly against both the Steel Curtain and the Rusty Trombones.

The commissioner argued to the Court that the Steel Curtain had no reason to acquire Jackie Battle because of the depth and talent of the running backs on his roster.  His roster consisted of Adrian Peterson, Frank Gore, DeMarco Murray, Ryan Mathews and Darren Sproles.  While it certainly doesn’t seem as though the Steel Curtain had any need for Battle, that is not reason enough to negate the trade.  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).  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. 

The interesting thing is that the teams do not deny that they had an agreement in place to make these transactions.  In fact, their only defense is that their conduct does not constitute collusion in and of itself.  The Court disagrees.

Collusion is defined as a secret agreement or conspiracy especially for fraudulent or treacherous purposes.  While this definition has a much darker tone than what actually transpired within the context of a fantasy sports league, it doesn’t change the fact that the actions of the two teams involved in this scheme fall within its confines.  The Steel Curtain and the Rusty Trombones clearly had a secret agreement because no one else in the league knew about it.  The purpose of their agreement was fraudulent in nature because it was designed to circumvent the established rules and waiver order for the benefit of a team that shouldn’t have received it. 

When looking at the totality of the circumstances and the nature of the transactions 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.  Here, the parties do not deny that they had a pre-determined arrangement.  As a result, the Court can easily conclude that collusion existed.  See Tiger’s Blood v. Hulkamaniacs, 3 F.J. 58, 61 (July 2011).

Because the league rules specifically state that trades are permitted so long as they are free from collusion, the commissioner was within his right to deny the trade based on the fact that it was collusive in nature.  The Steel Curtain’s acquisition of Jackie Battle will be upheld as he rightfully obtained him through the waiver wire.  However, the Steel Curtain should be precluded from trading Battle for as long as he remains on his roster.  The logic behind this conclusion is that any further transaction stemming from the Steel Curtain’s acquisition of Battlewould be fruit of the poisonous tree.  The Steel Curtain can drop Battle at any time where he would return to the waiver wire and be eligible to be acquired by other teams.  Additionally, the Court recommends that the Steel Curtain and the Rusty Trombones be precluded from making any additional trades with each other for the remainder of the season.  Their conduct has created an environment where any actions they take will be closely scrutinized under a microscope and questioned for its validity.  To prevent any further damage to the integrity of the league, it is best that they not be able to trade with each other again.

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.  See Doe v. Roe, 3 F.J. at 200.  There is no justification whatsoever for this type of conduct by either team.  The net impact this trade would have had on the league is unknown, but the conduct itself cannot be tolerated under any circumstances.  The trade between the Steel Curtain and the Rusty Trombones should be rejected, and limitations should be placed on their ability to trade with each other going forward to prevent any further impropriety.

IT IS SO ORDERED.

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