Pelham Bay Keeper League vs. Squatch’s Squad – 6 F.J. 447 (July 31, 2014) – Fantasy Baseball Dispute (Enforcement of Rules)

SUPREME COURT OF FANTASY JUDGMENT

Pelham Bay Keeper League vs. Squatch’s Squad

ON PETITION FOR WRIT OF CERTIORARI FROM
THE PELHAM BAY KEEPER LEAGUE

Decided July 31, 2014
Cite as 6 F.J. 447 (July 2014)

Factual Background

A head-to-head points-based fantasy baseball league called the Pelham Bay Keeper League (hereinafter referred to as “PBKL” was established in 2002 and is hosted on CBS.  The PBKL is a 12-team daily mixed AL/NL keeper league where GM’s play against two other teams every week.

During the current scoring period, Squatch’s Squad is playing against both the Bronx Bombers and Hilltop Hens.  On Wednesday, July 30, 2014, Squatch’s Squad left two starting pitchers on his bench – Alfredo Simon (SP-CIN) vs. Arizona (Wade Miley) and Dallas Keuchel (SP-HOU) vs. Oakland (Jason Hammel).  Based on the results obtained by Simon and Keuchel, Squatch’s Squad had 51 points sitting on his bench.  By the end of July 30, 2014, Squatch’s Squad had 186.33 points, the Bronx Bombers had 200.33 points, and the Hilltop Hens had 221.33 points.

The PBKL has the following rules regarding illegal lineups:

Rule 6.2

Illegal lineups after the All Star Break – (only applies to owners that are decided by the Commissioner Committee to be jeopardizing league integrity, whether it’s due to not paying attention or whatever reason). If that owner has an illegal lineup, the commissioner committee will contact that owner as soon as it is known to them to have the owner make their lineup legal. If, after contacting the owner, the lineup is not fixed or continues to be a problem, the committee will do what they feel is best for league integrity (Ex -make their lineup legal).

Lineups lock five minutes prior to the first game of each day.  On July 30, 2014, there was a 12:35 PM game between the Diamondbacks and Reds which meant that lineups locked by 12:30 PM.

Procedural History

The commissioner committee reached out to Squatch’s Squad later on July 30, 2014 and asked him if he forgot to set his lineup.  Squatch’s Squad’s response was that he didn’t realize there was an early day game and lineups locked before he could fix his lineup. This came on the heels of
Squatch’s Squad also forgetting to set his lineup one day during the previous week when, coincidentally, Alfredo Simon was also pitching.

Issue Presented

(1)   Should the commissioner committee take any action against Squatch’s Squad?

Decision

As important as it is to follow the language of the league’s Constitution and the rules set forth therein, it is equally as important to understand the theory and rationale that exist behind each rule.  See A New Hope vs. On the Juice, 1 F.J. 4, 7 (September 2009).  The Court understands why Rule 6.2 exists in the PBKL in order to uphold the integrity of the league by preventing GM’s from being uncompetitive.  The rule does not single out intent on behalf of the alleged offender.  In fact, the rule regarding illegal lineups contains a “catch-all” clause when it says it “only applies to owners that are decided by the Commissioner Committee to be jeopardizing league integrity, whether it’s due to not paying attention or whatever reason.”  This is problematic for the league.

Before we delve into the analysis of the rule itself and how it applies, we must acknowledge that it is every GM’s personal responsibility to enter and submit their lineups correctly.  See Didn’t Hit Submit vs. Commissioner, 1 F.J. 23, 25 (January 2010).  Of course, situations can arise which prevent a GM from being able to set a correct lineup whether it be a technological issue or a personal conflict.  Either way, it is conceivable to expect that GM’s may occasionally have lapses from inputting updated or correct lineups in daily leagues.

Here, Squatch’s Squad apparently did not set a full lineup last week when he kept Alfredo Simon on his bench on a day when he was starting.  Simon ended up pitching poorly so the outcome worked out well for Squatch’s Squad.  That leads to the question of whether Simon’s omission was intentional or not, followed by the question of whether it was proper for him to strategize by leaving Simon on the bench because he did not feel it was a beneficial matchup.

The Court has consistently ruled that people who participate in fantasy leagues should be given the freedom to manage their teams according to their own preferences.  Whether success is bred from that individual’s decision-making is purely left to some skill, luck, dedication, and savviness.  See Gangrene Master Yoda vs. Team Dizzle, 4 F.J. 284, 285 (October 2012); 4 Ponies vs. Carson City Cocks, 3 F.J. 13 (May 2011).  While Squatch’s Squad is in last place, there are no known allegations that he is either tanking on purpose or constructively abandoning his team.  Either of those scenarios might be cause for recourse.  What we have here appear to be much more innocent that either of those other scenarios.

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).  Based on the information provided to the Court, it does not appear that Squatch’s Squad is acting in bad faith.  While he was wrong for not setting his lineup correctly on July 30, 2014, he had a viable reason that he was unaware that there was a 12:35 PM game that day.  It doesn’t excuse his actions, but it certainly mitigates against any premeditated malevolent intent.

The commissioner committee wants to know whether they should invoke Rule 6.2 to go in and adjust Squatch’s Squad’s lineup.  The Court concludes that they should not do such a thing for a variety of reasons.  First, the rule as it is written is flawed.  The circumstances by which the rule grants the committee the ability to intervene is completely vague.  Vague and ambiguous language in a league’s constitution or written rules will be interpreted for the benefit of the league member.  General Zod vs. League Commissioner, 4 F.J. 303 (November 2012).

Second, if the league’s desire is to prevent illegal lineups then there should be a corresponding penalty in place.  If a rule is written prohibiting a specific action, there should be punishments delineated for violation of such a rule to make it enforceable.  Cannon’s Cripples vs. Hollifield’s Heroes, 5 F.J. 301, 304 (December 2013) (holding that it would be against public policy to penalize a violation of one of the transactions rules when no penalty is called for and the fact that the commissioner has overlooked at least three prior violations of the same rule).  Here, there is no direct penalty assessed against an offending league member.  Rather, the only recourse is for the commissioner committee to arbitrarily readjust the improper lineup.  This is not an effective deterrent for preventing such actions.

Third, the record is devoid of any information regarding how the PBKL defines an illegal lineup.  It very well may be defined in the rules, but we can only base our decision on the information provided and currently available.  What is defined as a correct or legal lineup is determined on a case by case basis according to each individual league’s rules.  See Awful Mitigators vs. Skeletors, 4 F.J. 316 (December 2012) (holding that the removal of starting players leaving empty slots in a lineup prior to a Monday night game is not illegal if the league doesn’t have any rules prohibiting it).  Since we don’t know whether Squatch’s Squad had two empty slots in his starting lineup or simply chose to leave Simon and Keuchel on his bench, we must give the GM the benefit of the doubt much the same way we did earlier with the vague and ambiguous language in the rule.

Finally, the fact remains that Squatch’s Squad is a paying member of the league who has the right to manage his team as passively or actively as he chooses so long as there is no collusion or pre-arranged agreements with other teams.  It appears as though the omissions of Simon and Keuchel on July 30 were unintentional.  However, even if they were intentional it falls in line with his right to manage his own team accordingly.  It would be another story if he left Clayton Kershaw and Adam Wainwright on the bench on a day where they both started.  We cannot ignore the very real possibility that some GM’s elect to bench certain players in order to avoid negative points.  That doesn’t appear to be the case here, but if it was then the commissioner committee would be grossly overstepping its authority by infringing on a GM’s managerial rights.

We understand the desire to maintain an equal playing field and have all teams remain competitive for the duration of the season.  But it would create a dangerous slippery slope if the commissioner committee invoked Rule 6.2 as it is currently written under these circumstances.  It may not be ideal to have an incomplete lineup in play, but choosing to enforce Rule 6.2 poses greater danger to the league in terms of overall fairness.  See Miguel’s Mashers vs. Detroit’s Finest, 3 F.J. 19, 21 (May 2011).  Based on the foregoing, the Court holds that the commissioner committee should not take any action with respect to adjusting lineups and rosters.  If Squatch’s Squad or any other team fails to field a complete and legal lineup, repeated emails should be sent with warnings that continued behavior will lead to possible suspension or expulsion from the league.  Immediate action under Rule 6.2 should only be reserved for extreme instances where a GM fails to set any lineup or there is proof that a GM is manipulating its lineup intentionally to affect the overall standings.

IT IS SO ORDERED.

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