PrimeTime vs. The Swani – 4 F.J. 220 (August 2012) – Fantasy Football Draft Collusion (A.Rodgers/RG3)

SUPREME COURT OF FANTASY JUDGMENT

PrimeTime vs. The Swani

ON PETITION FOR WRIT OF CERTIORARI FROM THE FRIE MONEY FOR THE ROOKIE FANTASY FOOTBALL LEAGUE

Decided August 30, 2012
Cite as 4 F.J. 220 (August 2012)

Factual Background

A fantasy football league called Frie Money for the Rookie (hereinafter referred to as “FMFTR”) has been in existence for 13 years and is comprised of 16 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 FMFTR is a dynasty league hosted on the MyFantasyLeague.com (“MFL”) fantasy football platform.  Teams are permitted to keep any player for an unlimited number of consecutive seasons.  Each team has a salary cap of $53.00 for the 2012 season which has increased by $5.00 per year since 2010.  Players’ salaries are determined by their weekly scoring average from the previous season (i.e., Aaron Rodgers averaged 27.5 points per week in 2011 so his 2012 salary is $27.50).  Keepers must be declared by July 31 each year.  On August 1 the salary cap is no longer in effect.

The league utilizes a customized scoring system on MFL which is broken down as follows:

Passing: 6 points per touchdown, 9 points per 50+ yard touchdown, 3 point bonus for 300 yards, 1 point per 50 yards, -1 point for a lost fumble, and -3 points for an interception.

Rushing/Receiving: 6 points per touchdown, 9 points per 50+ yard touchdown, 3 point bonus for 100 yards, 1 point per 15 yards, and -1 point for a lost fumble.  There are no points per receptions.

The league commissioner informed the Court that starting in 2013 the scoring for rushing and receiving yards will change to a decimal system, and the 100 yard bonus will be eliminated.

Starting lineups consist of the following: 1 QB, 2 RB, 2 WR, 1 TE, 1 K, and 1 D/ST.

The league is governed by a written set of rules which are posted on the league’s MFL website.  Trades are permitted between teams and must be considered fair in order for the commissioner to approve them.  

The FMFTR draft has already taken place.  The first overall pick (1.1) was Trent Richardson (RB-CLE) because that team already had Matthew Stafford (QB-DET) on his roster.  The Swani owned the 1.2 and 1.3 picks.  He selected Robert Griffin, III with the second overall pick and explained that he took Griffin over Aaron Rodgers for the “wow effect.”  After drafting Griffin, The Swani traded the 1.3 pick to PrimeTime in exchange for the 1.4 and 3.12 picks.  PrimeTime then selected Rodgers at 1.3 and The Swani selected Doug Martin (RB-TB) at 1.4. 

Procedural History

Keepers had to be declared before August 1, 2012.  In July, PrimeTime called The Swani to inform him that he was not keeping Rodgers because he was too expensive within his salary cap.  The two teams allegedly agreed in principle on a trade whereby The Swani would pass on Rodgers at 1.2 and then would trade 1.3 in exchange for 1.4 and 3.12.  Pursuant to the league rules, this trade could not be announced until the day of the draft, which it was. 

Throughout August 2012 after keepers had been declared, The Swani received several trade offers from other teams for the 1.2 pick knowing full well that Rodgers would be available after Richardson was taken first.  The Swami rejected all offers including a 1.5, 1.13 and a 2013 1st round pick, as well as Cam Newton (QB-CAR) and the 1.10 pick.  Instead, he opted to make the draft day trade with PrimeTime which allowed PrimeTime to get Rodgers.

This trade was made on the heels of another controversial trade made between these same two teams in 2011.  During Week 6 of the 2011 NFL season, The Swani traded Roddy White (WR-ATL) to PrimeTime in exchange for Stevan Ridley (RB-NE).  The Swani was 3-4 at the time and argued that he was out of the playoff race despite the playoffs not starting until Week 14 with eight teams earning berths. 

The commissioner along with other members of the league suspect possible collusion between these two teams.  Several league members believe these two teams are colluding whereby PrimeTime comes out ahead on every deal made with The Swani not receiving equitable compensation for the value he is trading away.  In addition, the commissioner believes that The Swani has turned down more valuable offers in order to trade with PrimeTime. 

The commissioner has submitted this case to the Court seeking an opinion on whether the draft day trade between PrimeTime and The Swani should have been approved, as well as whether any action should be taken against either of these teams as a result of suspected collusion.

Issues Presented

(1)   Should the 2012 draft day trade between PrimeTime and The Swami be revoked?

(2)   Should the 2011 trade between PrimeTime and The Swami have been allowed?

(3)   Is there justification for removing PrimeTime and/or The Swami from the league?

Decision

I.          SHOULD THE 2012 DRAFT DAY TRADE BETWEEN PRIMETIME AND THE SWANI BE REVOKED?

The case presented to the Court is a delicate one because it raises questions over possible collusion taking place during a draft day trade.  The draft is truly the cornerstone of any fantasy league and should be treated with sanctity, fairness, and equity.  It is imperative that any decisions made surrounding the draft be intelligent, objective, and for the benefit of the entire league because this is where people create and build their teams.  Mayor Goldie Wilson vs. Balloon Knots 3 F.J. 164, 166 (September 2011).

The commissioner and other members of the league suspect collusive conduct between PrimeTime and The Swami.  Collusion is defined as a secret agreement or conspiracy especially for fraudulent or treacherous purposes.  Steel Curtain vs. Rusty Trombones, 3 F.J. 201, 203 (November 2011) (holding that a secret agreement between teams to use the first waiver position as a means to move a player to another team further down the list was collusive because its purpose was to circumvent the established rules).

When presented with allegations or suspicions of collusion, the Court will look at the evidence in the light most favorable to the accused.  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 vs. Samcro Reaper Crew, 3 F.J. 177, 179 (October 2011).  As such, we must give the benefit of the doubt to PrimeTime and The Swani when analyzing their conduct.

The issue at hand is whether the trade between these teams for draft picks coupled with an alleged verbal agreement to pass on Aaron Rodgers is considered collusion.  The league rules state that offseason trades cannot be announced until the draft.  However, there is no indication that teams cannot talk amongst themselves to lay the groundwork for future deals.  It is apparent from the testimony provided that PrimeTime and The Swani did engage in discussions about making a trade at the draft.  This, by itself, is harmless.

The gray area comes in when there is suspected that an arrangement was in place for The Swani to pass on Rodgers to allow PrimeTime to select him with the very next pick.  The reason this raises suspicion is because Rodgers is clearly an elite fantasy player and arguably the best quarterback in the NFL.  See Steelers vs. Patriots, 3 F.J. 216, 220 (November 2011) (holding that trades involving elite players require additional scrutiny because of how valuable they are in terms of statistical production and name recognition).

While it is logical for people to question why The Swani would willingly pass on Rodgers and select Robert Griffin, III instead, the Court will not consider whether a decision is objectively intelligent or popular amongst league members in its analysis.  4 Ponies vs. Beaver Hunters, 3 F.J. 26, 27 (June 2011).  The Court will evaluate the objective merits of a deal and ensure that the integrity of the league is maintained.  See Victoria’s Secret vs. C-Train, 2 F.J. 32, 35 (October 2010).  It is alleged that other teams made better offers for The Swani’s 1.2 pick which he rejected.  Teams are not obligated to shop players around for a more advantageous deal solely to appease skeptical league members.  Road Runners vs. Urban Achievers, 3 F.J. 47, 50 (June 2011).

When playing in a dynasty league, fantasy players must consider the current season as well as future ones.  Grave Diggers vs. Chilidogs, 4 F.J. 5, 8 (January 2012); see also Harem Hawkings vs. Harbor Yankees, 4 F.J. 40, 42 (April 2012) (holding that a more expensive player could be financially prohibitive in the long run compared to a cheaper player who offers more financial flexibility).  While Rodgers is clearly the best available quarterback in the FMFTR’s draft, he will be financially prohibitive going forward due to his anticipated and expected production.  Remember, his keeper salary will be equivalent to his average weekly point total for the season.  It is plausible that The Swami willingly passed on Rodgers because he did not want to occupy half of his keeper salary cap on one player.

In addition, Robert Griffin, III is a highly touted rookie quarterback with tremendous upside.  The performance of Cam Newton in 2011 has created expectations for Griffin who has the potential to emerge as a very good fantasy quarterback due to his strong throwing arm and ability to run.  More likely than not, Griffin will have a lower average weekly point total which could make him more appealing to keep for future seasons than Rodgers.  It could also be that The Swani has a personal affinity for Griffin which could have motivated him to consent to this trade.  If this is the case, it is not up to the Court or anyone else to pass judgment.  See Los Pollos Hermanos v. Little Stumps, 3 F.J. 192, 194 (October 2011) (holding that a league member’s personal affinity with a particular player or team is irrelevant in analyzing whether a trade is fair and equitable).

At the end of the day, The Swani ended up with Robert Griffin, III, Doug Martin, and an extra 3rd round pick.  Because The Swani never owned Rodgers in the first place, he cannot be considered to have traded him.  It is true that he could have drafted him with the 1.2 pick, but he didn’t.  As a result, this cannot be considered a true trade of Rodgers in exchange for Griffin and the 3.12 pick.

The Court acknowledges that there was likely a verbal agreement between the teams for The Swani to pass on Rodgers.  This is what will be considered in terms of whether there was any collusion.  Without a confession or some form of written proof, the Court will rely on circumstantial evidence and weight the totality of the circumstances.  See John Doe vs. Richard Roe, 3. F.J. 197, 200 (October 2011).  The Court can draw inferences from the evidence to determine whether collusive conduct is present.  See Tiger’s Blood v. Hulkamaniacs, 3 F.J. 58, 61 (July 2011).

There is no evidence presented that these two teams are sharing a financial interest in their teams or the annual outcomes.  See League Commissioner vs. Judges, et al. 3 F.J. 223, 225 (December 2011) (holding that having a financial interest in more than one team is an indicator that collusion may be present).  There is also no indication that any league rules were violated or undermined.  Part of the argument made in support of the commissioner’s allegation is the fact that these two teams have a propensity for making trades with each other, which allegedly favor PrimeTime.  However, collusion cannot be proven merely because two teams consistently make trades with each other.  Fantasy players are not under any obligation to trade with people they do not want to.  Garbage Pail Kids vs. Alex P. Keaton & Co., 4 F.J. 84, 87 (June 2012).

People pay money to participate in fantasy leagues, and generally they should be afforded the freedom to manage their team accordingly.  Whether success is bred from that individual’s decision-making is purely left to some skill, luck, dedication, and savviness.  4 Ponies vs. Carson City Cocks, 3 F.J. 13 (May 2011).  There are certainly arguments to be made that The Swani’s decision to draft Griffin over Rodgers will not lead to success this season, or even in the future.  But The Swani, like every other team, is entitled to build his team according to his own subjective evaluation, strategy and desire.

When looking at the totality of the circumstances, the Court concludes that the actions of both teams do not rise to the level of collusion.  There was clearly an agreement in place for how to handle the draft, but this agreement was not fraudulent, nor was it made for the purpose of undermining any rules for a mutual benefit.  Based on the foregoing, the draft day trade between PrimeTime and The Swani should be upheld.

.II.        SHOULD THE 2011 TRADE BETWEEN PRIMETIME AND THE SWAMI HAVE BEEN ALLOWED?

The commissioner has asked the Court to determine whether a trade made between PrimeTime and The Swani in 2011 should have been allowed.  Normally there is no statute of limitations for submitting a case to the Court.  However, under the legal doctrine of laches, a claimant is barred from recourse due to an unreasonable delay seeking relief.  Bryan LaHair Club For Men vs. League Commissioner, 4 F.J. 26, 28 (April 2012).

The trade at issue in 2011 was The Swani trading Roddy White (WR-ATL) to PrimeTime in exchange for Stevan Ridley (RB-NE) during Week 6.  The Swani was 3-4 at the time and claimed he was out of contention for the playoffs.  When a team owner in a keeper league no longer believes he has any hope for contending in the current season, he must make critical roster management decisions of whether to trade off established players in exchange for unknown entities in building for the future.  Winners vs. Seven Shades of Shite, 3 F.J. 97, 102 (July 2011). 

The commissioner stated that there was still seven weeks left in the regular season with double-headers to be played.  He argued that The Swani’s justification was unfounded.

When a case is submitted requesting retroactive adjudication, the Court will only consider the facts, circumstances, and statistics as of the date of the incident.  All subsequent details will not be part of the analysis.  See Steelers vs. Patriots, 3 F.J. 218 (November 2011).  This trade was made after Week 6 of the 2011 season.  At that time, White only had 373 yards and two touchdowns – hardly elite production.  While Ridley did not play often and only had one game with 97 yards, he was still part of New England’s potent offense. 

The record is devoid of how each teams’ roster was comprised at the time, so the Court cannot make any assessment of their respective needs.  While the trade does not look even on paper, it was not so grossly lopsided to warrant rejection.  Had White been producing as he normally did at that time, then perhaps the analysis would be different.

Based on the foregoing, the 2011 trade between these teams was correctly approved.

III.       IS THERE JUSTIFICATION FOR REMOVING PRIMETIME AND/OR THE SWANI FROM THE LEAGUE?

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 vs. Richard Roe, 3 F.J. 197, 199 (October 2011); Going, Going, Gonzalez vs. Fantasy Baseball League, 1 F.J. 29, 30 (May 2010). 

The commissioner is clearly disturbed enough by the actions between PrimeTime and The Swami to inquire whether there is just cause for removing either or both of them from the FMFTR.  However, as the Court has previously decided, the actions between these teams do not give rise to collusive conduct.  That does not mean that their actions are not cause for concern.

Based on the foregoing, the Court does not recommend removing either team from the league at this point.  See Bald Eagles v. Weasel D, 3 F.J. 205, 210 (November 2011) (holding that the Court may intervene and prevent excessively harsh punishment when the consequences do not equate with an alleged offense including expelling a team from a league by classifying an inequitable trade as collusive)

The Court recommends that the commissioner address these concerns with both teams and explain the perception that their interactions and dealings have on the rest of the league.  However, if the commissioner is not satisfied with any explanations provided or if this type of conduct continues where there is constant speculation and skepticism, then the commissioner should revisit the decision to remove either team from the league.  At the end of the day, the commissioner must maintain the integrity of the league at all costs.  If the commissioner determines that either or both teams are disrupting the integrity of the league, then he retains the right to remove them at his discretion. 

IT IS SO ORDERED.

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