Bryan LaHair Club For Men vs. League Commissioner – 4 F.J. 26 (April 9, 2012) – Fantasy Baseball League Schedule Dispute

SUPREME COURT OF FANTASY JUDGMENT

Bryan LaHair Club For Men vs. League Commissioner 

ON PETITION FOR WRIT OF CERTIORARI FROM THE SECOND CITY FANTASY BASEBALL LEAGUE

Decided April 9, 2012

Cite as 4 F.J. 26 (April 2012) 

Factual Background

A fantasy baseball league called the Second City Fantasy Baseball League (hereinafter referred to as “SCFBL”) is comprised of 14 teams and has been in existence since 2009.  The SCFBL, hosted on CBSSports.com, is a head-to-head (“H2H”) points league that utilized a snake draft format and auction bidding on free agents when making transactions.  It is a mixed AL/NL keeper league where each team may keep a maximum of five (5) players from its 25-man roster.    

Given that the SCFBL is a H2H points league, each team plays a scheduled game against another team during a particular scoring period.  Statistics are assigned point values, and at the end of the scoring period, the team with more points based on their players’ performances earns a victory in the standings.

Before the season started and prior to the SCFBL draft, which took place on March 25, 2012, the league commissioner entered the entire season’s schedule utilizing CBSSports.com’s commissioner services.  In this package, the commissioner is able to customize scoring periods to be as short or as long as desired.  Once the schedule is input and saved properly, each team in the league is able to access schedules for their own teams and the entire league to view each matchup.  The commissioner informed the league once this task was completed on March 22, 2012.

When the commissioner entered the schedule, he set the time frame for the first scoring period to begin on March 28, 2012 and conclude on April 8, 2012.  This scoring period included the games in Japan between the Oakland Athletics and Seattle Mariners, as well as the games played between April 4-8, 2012.  Under normal circumstances, a scoring period will go from Monday through Sunday.  However, because of the MLB schedule, the scoring period was extended over a period of two weeks but included fewer games than normal.

Procedural History

At no time before the draft or after the MLB season began did any SCFBL team raise any concerns or make any complaints to the league commissioner regarding the schedule.  During the draft, the commissioner also reiterated to the league that the Japan games would count towards Week 1, which was set to conclude on April 8.  On March 27, 2012, the commissioner also distributed an email to the entire league reminding everyone to set their lineups before the Japan games began because lineups would be locking at that time.

Additionally, when transactions were made after lineups locked on March 28, 2012, each team received a notification that the transaction would be effective for Week 2 beginning on April 9, 2012.

On April 8, 2012, the owner of the team called Bryan LaHair Club For Men emailed the commissioner and voiced his displeasure at the fact that Week 1 was concluding on April 8 rather than be extended to include the entire following week.  His rationale was that not all pitchers had an opportunity to start because it was a shortened week and that it was too short a time frame to determine a win or a loss in the standings.  Bryan LaHair Club For Men requested that the first scoring period be extended and include games played between April 9-15.

The commissioner disagreed with Bryan LaHair Club For Men’s argument and denied his request for relief.  Bryan LaHair Club For Men now submits this appeal for review.

Issue Presented

(1)   Should the commissioner’s decision to leave the schedule as is be upheld?

Decision

Before analyzing the merits of this dispute, we must first discuss the timing of when everything transpired.  There is no statute of limitations on when an issue can be brought to the Court for review.   Bald Eagles v. Weasel D, 3 F.J. 205, 209 (November 2011).  However, whether recourse is available must be determined on a case by case basis.  Fluffy Bunny Feet vs. The Huxtables, 4 F.J. 23, 24 (March 2012).  In this case, it boils down to whether a reasonable amount of time has passed from when there could be recourse provided.

It is unknown whether the SCFBL has a written constitution or not.  However, it is irrelevant whether they do or not in this instance.  The commissioner is presumably the only person with access to the league’s settings, and therefore, is solely responsible for the administration of the league in that regard.  Given this is the SCFBL’s fourth season, it is safe to assume that most, if not all, league members are familiar with this process by now.

After the league schedule was input, the commissioner informed all league members that the task was completed.  At that time, all members were on notice of the schedule and made aware of when Week 1 would be taking place.  No complaints or challenges were made at that time.  Then at the SCFBL draft, the commissioner once again reiterated what the Week 1 schedule was.  This second notice reinforced the fact that all league members tacitly assented to the settings and schedule entered by the commissioner.  See Id. (holding that acceptance of the manner in which trades are reviewed can be determined by the lack of dissent or challenge to such rules over the course of time).

The fact that this complaint was not raised until the day before the scoring period concluded undermines the appellant’s right to recourse.  He had ample opportunity to voice concerns over the schedule dating back to March 22, 2012 when it was first generated by the commissioner.  Under the legal doctrine of laches, a claimant is barred from recourse due to an unreasonable delay seeking relief.  That applies in this case as the appellant failed to seek relief within a reasonable amount of time, and any such recourse sought would unduly prejudice the commissioner and the rest of the league.

Irrespective of whether the appellant is barred from obtaining relief in this case, there is no justifiable reason to undermine the settings of the league.  The commissioner is empowered with the tasks of creating the league’s rules, settings, and guidelines.  Along with these responsibilities comes an inherent grant of authority and autonomy to run and administer fantasy sports leagues.  See Flemish USA v. League Commissioner, 2 F.J. 35, 36 (October 2010) (holding the league Commissioners are entitled to arbitrarily make decisions that do benefit the league as a whole).

The record is devoid of any information regarding league members’ ability to challenge decisions by the commissioner.  However, even if there was an internal appellate process, its scope would fall outside the parameters of the league schedule.  Perhaps if there was an initial challenge to the schedule when it was created there could be some justification for exploring remedies.  But there is no indication that any team voiced a complaint about the league schedule at any time prior to April 8, 2012.

The truncated schedule for Week 1 of the SCFBL applied equally to all teams.  The fact that there were only three or four MLB games during this scoring period handicapped the entire league and did not unduly prejudice anyone moreso than anyone else.  Because all teams were on equal footing, no one can claim any inherent disadvantage. 

Based on the foregoing, the Court denies the appellant’s appeal and further upholds the league’s existing schedule.  The commissioner utilized his powers to create and enter the league schedule before the draft took place.  There are no allegations of foul play or impropriety against the commissioner.  As such, the Court will not intervene or undermine the settings of the league.

IT IS SO ORDERED.

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