Awful Mitigators vs. Skeletors – 4 F.J. 316 (December 4, 2012) – Fantasy Football Roster Dispute (RGIII, M.Bennett)
SUPREME COURT OF FANTASY JUDGMENT
Awful Mitigators vs. Skeletors
ON PETITION FOR WRIT OF CERTIORARI FROM THE SUMMIT ATHLETIC CONFERENCE FANTASY FOOTBALL LEAGUE
Decided December 4, 2012
Cite as 4 F.J. 316 (December 2012)
A fantasy football league called the Summit Athletic Conference Fantasy Football League (hereinafter referred to as “SACFFL”) is comprised of ten (10) teams who 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. Of the ten teams, six (6) earn playoff berths beginning during the NFL’s Week 14. The SACFFL is hosted on the Yahoo fantasy football platform and is governed by the internal settings input by the commissioner.
During Week 13, the team known as the Awful Mitigators (which is managed by the league’s commissioner) played against the Skeletors. On the afternoon of Monday, December 3, 2012, the Skeletors removed Robert Griffin III (QB-WAS) and Martellus Bennett (TE-NYG) from his lineup, thus leaving two empty spots. The Monday night game on this date was the New York Giants versus the Washington Redskins.
The Skeletors were already assured a victory and a playoff spot irrespective of Griffinand Bennett’s production. The Skeletors did not want to accumulate any additional fantasy points for the week which would cause him to ascend the standings into 5th place and force a matchup against the 4th place team. Rather, the Skeletors preferred to remain in 6th place with a more favorable matchup against the 3rd place team who has been struggling.
There are no rules in the league’s settings which cause an automatic disqualification or any other form of penalty for having an incomplete or illegal roster. There are also no rules or league precedent for handling such a scenario where an individual team manipulates his own lineup in this manner to assure a certain placement in the standings.
Because there are no rules prohibiting such a maneuver, the Skeletors incomplete lineup remained legal and was awarded the victory despite having empty slots at quarterback and tight end. The commissioner believes that the Skeletors’ actions go against the spirit of competition. The commissioner also submitted to the Court that this would not have been an issue if the Skeletors would have added rarely used backups at each position on the Giants or Redskins to ensure that complete lineups were being used. He now seeks an opinion from the Court on whether the Skeletors’ actions were so egregious as to warrant overriding the system and placing Griffin and Bennett back in his lineup retroactively.
(1) Should the commissioner be allowed to add back Griffin and Bennett’s points to the Skeletors’ final score?
The SACFFL is not governed by a constitution or written set of rules outside of the settings and parameters chosen by the commissioner on the league’s Yahoo website. The commissioner is empowered with the tasks of creating the league’s rules, settings, and guidelines. Bryan LaHair Club For Men vs. League Commissioner, 4 F.J. 26, 28 (April 2012). When a league does not have a written constitution, the commissioner will typically have the final say on issues that fall outside the scope of the league’s host site’s parameters. Dwayne Bowe Peep vs. The Boston Tea Party, 3 F.J. 188, 190 (October 2011).
Without a constitution, the commissioner must rely on precedent, common sense, and the best interests of the league when making critical decisions. Didn’t Hit Submit vs. Commissioner, 1 F.J. 23, 26 (January 2010). While commissioners should have a certain amount of discretion and autonomy to run a fantasy league, they must balance the interests of their own franchise with the best interests of the league overall. Determining whether that line has been crossed is not always easy to ascertain. Cincinnati Bungles vs. O&A’s Two Point Conversion, 3 F.J. 88, 90 (July 2011).
The first thing the Court must look at is whether there are any rules or settings which penalize or prohibit a team from having an incomplete or illegal lineup. After reviewing the league’s settings, there is no penalty in place for having empty roster spots on a team’s lineup. But the analysis does not end there simply because there was no rule in place. Even if an individual is technically in compliance with the rules, his/her actions may still require Court intervention if it potentially jeopardizes the overall integrity of the league. League Commissioner vs. Judges, et al. 3 F.J. 223, 226 (December 2011).
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 argues that the Skeletors’ actions violate the spirit of the league and competition. If that is demonstrated to be true, then the Court must determine whether this rises to the level of severity to warrant intervention despite compliance with the rules.
It is undisputed that the Skeletors clinched a playoff berth on Sunday, December 2, 2012 with their victory against the Awful Mitigators. The margin of victory going into Monday night’s game was just less than 8 points. According to the Skeletors, he put Griffinand Bennett on his bench admittedly to avoid accumulating any more points which would have elevated him to the 5th seed in the playoffs. However, he also testified that part of his motivation was to keep them out of the game in the unlikely event they received too many negative points which could have cost him the victory and playoff berth. In the SACFFL, there are negative points awarded for various statistical categories such as incomplete passes, interceptions, and fumbles lost.
If there was a rule against having an illegal or incomplete lineup, then clearly this would have been a violation. However, no such rule was in place. The Skeletors also testified that other teams in the league have, on occasion, had players injured or on a bye week in their lineups without any critique or intervention by the commissioner. The Court cannot confirm or deny this, but based on the commissioner’s submission it seems as though this particular incident stood on its own simply for the fact it had serious playoff seeding implications.
The fact remains that it is every fantasy league member’s personal responsibility to enter and submit their lineups correctly. Didn’t Hit Submit vs. Commissioner, 1 F.J. at 25. What is defined as a correct or legal lineup is determined on a case by case basis according to each individual league’s rules. In this case, there is no definition of what an illegal lineup is because there is no penalty in place for having an empty roster spot. Because of that, it can only be concluded that the Skeletors’ lineup was legal.
As a recommendation, the commissioner should modify the rules for 2013 to include an automatic disqualification for an illegal lineup if this is something he is concerned about happening again. Clearly the commissioner did not foresee this as a possible issue because it had never happened before. Commissioners are not expected to reasonably foresee every possible situation that can arise during the season. Holding them to such a standard would be unfair. Z Wolves, et al. vs. League Commissioner, 3 F.J. 212, 216 (November 2011).
There are rare instances where it is justifiable to deviate from the established rules or manner in which issues are handled in the middle of a season. Typically, game results, standings, and scores should never be modified, overturned or changed unless there was an obvious scoring mistake by a stat server or proof of cheating or collusion. Didn’t Hit Submit vs. Commissioner, 1 F.J. at 27.
The commissioner should maintain consistency with the enforcement and implementation of all rules and guidelines. If an exception is warranted, there should be an objective and rational basis premised on the overall best interests of the league. See Machine vs. League Commissioner, 2 F.J. 1, 3 (September 2010). This leads to the final part of the analysis where the Court takes exception to the commissioner’s partisan interest in this issue.
In most leagues, the commissioner is also one of the league members competing for the same goals as everyone else. It is irrefutable that commissioners are entitled to manage their teams in the same manner as others in an attempt to succeed. See A-Holes & Pujols vs. Mad Cow Disease, 3 F.J. 44, 46 (June 2011); see also Johnny Bench’s Baseball Bunch vs. Yuniesky Betancourt’s Revenge, 4 F.J. 13 (February 2012) However, they must balance their own personal interests with the interests of the league overall.
In this case, the commissioner has an obvious conflict of interest. His team is competing for the same playoff position as the Skeletors where both prefer to have the 6th seed as opposed to the 5th seed. The Skeletors’ decision to benchGriffin and Bennett prior to the Monday night game had a direct detrimental impact on the commissioner. For the commissioner to now make an unprecedented claim that the Skeletors’ actions constituted a violation of the spirit of the league appears to be self-serving and biased. He cannot arbitrarily enforce a rule that does not exist, especially when there is a logical basis for doing what the Skeletors did. The Skeletors earned the right to make a roster decision on Monday in order to secure a victory and obtain the most preferred and beneficial playoff position in his estimation.
Playing Devil’s advocate, the Skeletors are well within their right to do this. However, they clearly took advantage of a loophole in the league’s rules which, for whatever reason, omitted a penalty for an illegal lineup. Despite that, this is part and parcel of the strategy that goes in fantasy football when a team has the rare luxury to essentially choose their own playoff opponent. It could also be quite a different analysis if the Skeletors’ actions were taken to either ensure or prevent another team from earning a playoff berth. Here, both the Skeletors and Awful Mitigators were in the playoffs regardless.
Based on the foregoing, the Court denies the commissioner’s request to addGriffinand Bennett’s points to the Skeletors’ score. The Skeletors did not violate any rules, and they had valid and justifiable reasons for managing their roster according to their own preferences. Finally, the commissioner had a clear conflict of interest in making this request to the Court. We recommend modifying the SACFFL’s rules for 2013 to prevent this type of lineup manipulation if there is a concern it could happen again.
IT IS SO ORDERED.