Fair and Balanced vs. League Commissioner – 5 F.J. 1 (January 19, 2013) – Fantasy Baseball Dispute (Commissioner’s Discretion)

SUPREME COURT OF FANTASY JUDGMENT

Fair and Balanced vs. League Commissioner

ON PETITION FOR WRIT OF CERTIORARI FROM
THE LOOSE CANNONS FANTASY BASEBALL LEAGUE

Decided January 19, 2013
Cite as 5 F.J. 1 (January 2013)

Factual Background

A fantasy baseball league called the Loose Cannons Fantasy Baseball League (hereinafter referred to as “LCFBL”) is comprised of 12 teams and has been in existence since 2008.  The LCFBL, hosted on Yahoo, utilizes an auction format for its annual draft and bidding on free agents when making transactions.  Each team has a draft budget of $260 and an after-auction salary cap of $300.  It is a mixed AL/NL keeper league where each team may keep a minimum of three (3) players and a maximum of ten (10) players from one season to the next within its 23-man roster. 

As with many rotisserie leagues, the LCFBL uses the standard 5×5 scoring categories to determine the standings and prize money.  For offensive players, the five categories are: (1) batting average; (2) homeruns; (3) runs batted in; (4) runs scored; and (5) stolen bases.  For pitchers, the five categories are: (1) wins; (2) earned run average; (3) WHIP (walks+hits/innings pitched); (4) strikeouts; and (5) saves.  Statistics are cumulative throughout the course of the season and there are no head to head games contained within the Roto league.

The league does not have a written constitution, but rather is governed by the settings input and selected by the commissioner within the Yahoo league website.  There is nothing contained in these settings that deals with the selection of replacements for league members who choose to depart from the league.

All 12 teams have remained in the league since its inception until the end of the 2012 season.  However, on January 18, 2013, the team known as “I Hate Manure” decided not to return to the league for the upcoming.  He informed the league commissioner of this decision.  The commissioner emailed the other league members asking if they had any suggestions or recommendations for people to replace I Hate Manure and inherit his team.  Two league members – “Fair and Balanced” and “The Insomniacs” replied that they each had someone in mind to join the league.

Procedural History

The Insomniacs sent their email first, and three hours later Fair and Balanced sent theirs.  The commissioner did not know either of the people suggested as replacements.  The backgrounds of both recommended people were similar in terms of their fantasy sports experience.  Because The Insomniacs sent his email first, the commissioner decided to accept his recommendation for a new member of the league.

Upon learning of this decision, Fair and Balanced protested the decision for a variety of reasons, none of which are relevant.  The commissioner reiterated his decision and welcomed The Insomniacs’ recommendation into the league.  Fair and Balanced has challenged this decision accusing the commissioner of abusing his discretion.

Issue Presented

(1)   Did the LCFBL commissioner abuse his discretion by choosing one new league member over another?

Decision

The Court is frequently presented with questions about the scope of a league commissioner’s authority and the potential abuse of discretion.  When a commissioner is bound by a constitution, it is generally easier to discern whether a decision falls within the ambit of the rules.  Ryan Braun’s Kosher Urine vs. League Commissioner, 4 F.J. 20, 21 (February 2012).  However, without a constitution, the analysis of whether a commissioner’s decision should be upheld requires a broader analysis.  See Afraid of Change vs. Fantasy Football League, 1 F.J. 11, 12 (September 2009) (holding that a commissioner’s unilateral decisions will be upheld so long as they are not self-serving and are in the best interests of the league). 

Commissioners should be granted a certain amount of discretion and autonomy to run a fantasy sports league.  Flemish USA vs. 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).  However, their decisions and actions must not be demonstrative of an abuse of such power.  Ascertaining this distinction is not always an easy task.  See Cincinnati Bungles vs. O&A’s Two Point Conversion, 3 F.J. 88, 90 (July 2011). 

Typically the Court will uphold a commissioner’s decision so long as it is in the best interests of the league overall.  Making decisions about the participants in the league is certainly something that will have an overall affect on all members.  In order to pass muster, the LCFBL commissioner must have made his decision with the league’s best interests in mind and without any self-serving motivation.

League commissioners are 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).  In addition, the commissioner is also responsible for filling voids in the league to ensure there are an appropriate number of teams.  In this case, the commissioner asked his fellow league members for suggestions and recommendations of people who could join the league.  This in and of itself demonstrates that the commissioner was not seeking any sort of personal gain by filling the spot with someone only he knew.  That is not to say doing so would be an abuse of power.  It simply demonstrates that the commissioner sought assistance from his league members and was willing to possibly admit a person into the league he did not know.

This was an unprecedented event because no team had ever left the league since its inception in 2008.  As a result, no procedures were in place to provide guidance on how to do so.  There were no rules or settings on the Yahoo league website related to this process.  When a league does not have a written constitution or specific rules, 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).

After the commissioner solicited recommendations, he received two from his league members.  He did not personally know either of them, and they allegedly possessed similar backgrounds in terms of fantasy baseball experience.  Rather than drag out the selection process, the commissioner simply opted for the The Insomniacs’ suggestion because he sent it first.  The Court sees nothing wrong with this.

It cannot be overstated how important it is for a league commissioner to be decisive and timely when making decisions that affect the overall administration of the league.  Because this is a keeper league, it was imperative to find a replacement immediately so that the new owner could effectively manage his team and consider any roster moves or transactions that could be on the horizon. 

The commissioner took appropriate measures by asking everyone else if they had suggestions for a replacement.  When presented with two options of apparent equal credibility, he simply opted for the suggestion that was made first.  He never laid out any ground rules or other procedures for this selection, nor did he have to.  Based on the foregoing, the Court upholds the commissioner’s decision to accept The Insomniacs’ recommendation for a new league member.  As a result, the Court rules that the commissioner’s actions did not demonstrate any semblance of an abuse of power or discretion.

IT IS SO ORDERED.

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