Ultimate HigWarriors vs. League Commissioner – 6 F.J. 478 (August 3, 2014) – Fantasy Baseball Dispute (Veto System)

SUPREME COURT OF FANTASY JUDGMENT

Ultimate HigWarriors vs. League Commissioner

ON PETITION FOR WRIT OF CERTIORARI FROM
THE WORLD CHAMPIONS LEAGUE

Decided August 3, 2014
Cite as 6 F.J. 478 (August 2014)

Factual Background

A fantasy baseball league called the World Champions League (hereinafter referred to as “WCL”) was established in 2003.  The WCL is a 12-team keeper league hosted on Yahoo! in which each team is allowed to keep four players each season. There is no limit on how long one team may keep a player. The WCL is a weekly, head-t-head roto league utilizing a 6×6 scoring system which includes the following categories: (R, HR, RBI, TB, SB, OBP, W, L, SV, ERA, WHIP, and K/9).  Six of the teams are owned by people who have been friends since grade school, while the other six are friends who have generally met in college or later.

The WCL is governed by a set of written rules which includes a provision known as The Fowles Clause relating to fair play and sportsmanship.  The rule, in pertinent part, states:

8.         Fair play (the Fowles clause):

Teams shall zealously play in a manner that promotes fair competition. Should any league member declare (whether orally, in writing, via electronic commutation or otherwise) a violation of this rule, and another team second the claim of a violation, the commissioner will contact the alleged rule violator and issue an order which will thereafter be precedent.

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Any owner may appeal an Order to http://fantasyjudgment.com (or if fantasyjudgment.com is unavailable, a similar neutral third-party internet fantasy sport appeal service). Any cost for appealing an Order shall be the responsibility of the appealing owner, regardless of whether the owner prevails upon appeal or not. . . .

The WCL also contains rules regarding the approval and rejections of trades, including vetoes.

7.         Trades

              c.         Vetoes

                          i.          All trades will be sent to Yahoo for a third party review. The price is $13 so everyone will pay a $1 service fee in addition to the $25 prize money. This means that a third-party independent Yahoo representative will review the trade at the price of $13 per person.

Based on this rule, the only way for a trade to get vetoed was by Yahoo’s trade arbitration service.  In 2013, this independent service was utilized.  However, it appears that due to a Yahoo! glitch, the ability to retain Yahoo’s independent representative was deleted unbeknownst to the league.  Somehow, league members have been able to vote on trades to determine whether they should be approved or rejected despite this not being the operative manner in which trades are adjudicated.  The Ultimate HigWarriors were not a party to any of those prior trades.

On July 29, 2014, the Ultimate HigWarriors agreed to a trade with Eff this Ish.  The Ultimate HigWarriors traded Manny Machado (3B-BAL) and a 5th round draft pick in 2015 to Eff this Ish in exchange for Jose Altuve (2B-HOU), Evan Longoria (3B-TB) and an 18th round draft pick in 2015.

On July 30, 2014, due to a glitch in Yahoo’s system, the trade was vetoed by the following four teams – The Curse of the Pujols, Over the Top, Gat Damn Yankees, and an unknown team.  The “four team” rule is nowhere to be found in the league rules.  The trade was resubmitted again on July 30 with Billy Butler (DH-KC) included along with Machado so that the Ultimate HigWarriors would not be over the 24-player roster limit.  Again, four teams were able to veto the trade due to a glitch in the system. The trade was submitted once more on July 31, 2014, and four teams vetoed the trade again.

Three of the opposing teams revealed themselves and explained that they vetoed the trade because it was unbalanced in favor of the Ultimate HigWarriors.  It is alleged that these teams that vetoed the trade are all in contention for the league championship and do not wish to see the Ultimate HigWarriors improve their team.   The owner of the team Eff this Ish also happens to be the commissioner of the WCL.

Procedural History

The Ultimate HigWarriors challenged the trade veto citing Rule 8 to the commissioner.  It was argued that the teams vetoing the trade were in violation of the fair competition clause.  The commissioner then ruled on these appeals denying the Ultimate HigWarriors’ requests for recourse.  The commissioner acknowledged his conflict of interest given that his own team was involved in the disputed trade that was vetoed.  However, he ruled that the veto of the original trade would be upheld since it would create additional controversy because of his own team’s involvement, as well as the fact that previous trades had also been subjected to the league vote where some had been rejected once four GM’s voted against it.

In addition, the WCL commissioner also decided to call for a vote to determine whether the league wanted to utilize a third party to review all trades.  As a result of this decision, the commissioner also proclaimed the following:

1. The league settings for trades will be switched to “Commissioner.”
2. All trades pending acceptance in the queue will be cancelled until the end of the vote.
3. All trades completed during the vote will be cancelled.
4. With the trade deadline approaching, this vote will go through on Sunday, August 3 and will be closed at 12:01 AM on Monday, August 4.
5. The vote will be placed on the Yahoo! league page.
6. The vote requires six “yes” votes to pass.
a. If the vote passes, then the settings will remain with “Commissioner” and the league will purchase a season package from Fantasy Judgment. At that   point, all trades will be open again and no longer immediately dismissed by the commissioner.
b. If the vote does not pass, then the settings will go back to as they have been for the rest of the season.

The Ultimate HigWarriors have submitted this appeal to the Court seeking to overturn the commissioner’s rulings.

Issues Presented

(1) Which method of review for trades should apply this year?
(2) Should the subject trade have been vetoed in the first place?

Decision

I.          Which Method of Review for Trades Should Apply This Year?

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).  Rule 7(c) was enacted in order to facilitate an independent trade review process for the whole league.  The purpose of this is to ensure objective and unbiased evaluation of trades and eliminate the potential for any impropriety when it comes to decision-making by fellow members of the league.

It is unfortunate for the WCL that Yahoo! discontinued its trade arbitration service, especially without providing their customers with proper notice.  As such, the WCL was unable to amend its rules in time to establish a different method by which trades would be processed.  The Court cannot comment on how or why trades were able to be voted on and vetoed by league members simply because Yahoo’s arbitration service had ceased to exist.  That is a technical issue which is out of our jurisdiction.  However, what is clear is that Rule 7(c) is does not contain any type of alternative manner for trade review.  There is no mention of a league voting process, let alone requirements for the number of votes needed to veto a trade.

We are not implying that the WCL commissioner should have amended the rule to include a backup plan.  League commissioners cannot reasonably foresee every possible issue or situation that can arise during a season.  To hold them to such a standard would be unfair.  See Z Wolves, et al. vs. League Commissioner, 3 F.J. 212, 216 (November 2011).  The point being made is that the intention behind the rule is to have trades reviewed externally, whether it was by Yahoo, Fantasy Judgment, or any other service.  There is nothing in the rules which discusses the league voting on trades to determine their approval or rejection.

The WCL commissioner is in an unenviable situation because of his conflict of interest which he openly acknowledged.  He seems aware of the possibility that his decision could be questioned because of his own team’s involvement in the underlying trade that is the subject of this dispute.  Commissioners are constantly under more scrutiny than the other members of the league simply because of the power and authority that is granted with such a position.  See America’s Team vs. The 1987 Denver Broncos are Cartman’s Father, 3 F.J. 51, 53 (July 2011).

The Ultimate HigWarriors have cited Rule 8 as their basis for appeal arguing that the teams that vetoed the trade were not acting in the spirit of fair competition.  While the Court agrees that they should not have even had the ability to veto the trade in the first place, their actions were not in bad faith.  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 teams that vetoed the trade believed they were acting in accordance with what the rules permitted based on earlier deals being handled the same way.  We do not find fault in their actions or motivations.

One of the arguments the Ultimate HigWarriors made against the teams that vetoed the trade was that they were all pursuing a league championship and were chasing the HigWarriors in the standings.  He claims that these teams vetoed the trade selfishly because they did not want him to improve his team.  This is one of the primary reasons why the Court does not endorse the league voting method to process trades.  League votes tend to inhibit people’s ability to make deals.  Generally, GM’s have their own agendas in mind so relying on all other league members to objectively vote on a trade doesn’t always lead to the fairest decisions.  Fixed Ops vs. Desert Cowboys, 5 F.J. 256, 258 (November 2013); Rubik’s Pubes vs. League Commissioner, 4 F.J. 98, 100-101 (June 2012).  This may in fact be what their motivations were, but that does not mean they were acting in bad faith if the rules do not expressly prohibit it.

The problem here is that the rules do not even expressly permit a league vote in the first place.  The intent is clear that the preferred method of adjudicating trades is through a third party.  Since Yahoo’s service was discontinued, the league has other options for similar services.  The need for this is amplified even more by the fact that the commissioner himself is involved in the disputed trade.  The rules as they are written should be honored as closely as possible.  The most logical decision on how to handle the disappearance of Yahoo’s arbitration service is to select a different third party service.  It would go completely against the grain to revert to a league voting method since that is the antithesis of independent trade review.  While other trades may have been effected by the league’s trade reviews earlier in the season, those deals can be resubmitted or renegotiated utilizing the third party service.

II.        Should the Subject Trade Have Been Vetoed in the First Place?

The HigWarriors have also asked the Court for an opinion on whether the trade of Manny Machado, Billy Butler and a 5th round pick in the 2015 draft in exchange for Jose Altuve, Evan Longoria, and an 18th round pick in the 2015 draft was appropriately vetoed.  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).

No evidence has been submitted indicating any alleged collusion or malfeasance.  As such, the Court will operate on the presumption that there is no collusive conduct between the parties.

The WCL is a keeper league which can lead to a different evaluation of a trade as opposed to a non-keeper or redraft league.  A trade that may look facially uneven or lopsided could easily pass muster in a keeper league.  Trades made between teams in a keeper league need to be analyzed by other factors besides merely comparing statistics.  Grave Diggers vs. Chilidogs, 4 F.J. 5, 8 (January 2012).  These other factors include salary cap flexibility, contractual status of players, and long-term planning at the expense of the current season.  Smittydogs vs. Moneyball, 1 F.J. 32, 33 (June 2010); Winners vs. Seven Shades of Shite, 3 F.J. 97, 102 (July 2011) (holding that team owners in keeper leagues with no hope of contending in the current season must make critical roster management decisions of whether to trade established players to help build for the future).

At first glance, the trade of Evan Longoria, Jose Altuve and an 18th round pick in the 2015 draft in exchange for Manny Machado, Billy Butler and a 5th round pick in the 2015 draft looks slightly inequitable in terms of present day value.  None of the players involved in this deal are considered elite for purposes of requiring additional scrutiny merely because of how valuable they are.  Steelers vs. Patriots, 3 F.J. 216, 220 (November 2011).  However, there are star players involved on both sides of the trade.

The HigWarriors are currently in 1st place and are clearly looking to maintain and lengthen their lead in pursuit of a championship.  As such, this trade helps bolster their roster for the remainder of the season.  Without knowing the composition of these teams’ rosters, we can infer that players like Altuve and Longoria represent upgrades at whichever roster position they will be utilized at.  See Moneymakers vs. Logan’s Heroes, 6 F.J. 73, 74 (April 2014) (holding that the Court can surmise the competing interests and priorities of the trading partners based on the players involved in the deal when the record is devoid of the teams’ rosters).  Further, the HigWarriors also have argued that they are unlikely to keep either Jose Altuve or Evan Longoria in future seasons since they are limited to four keepers which they will most likely use on Yasiel Puig (OF-LAD), Billy Hamilton (OF-CIN), Anthony Rizzo (1B-CHC), and Jose Abreu (1B-CHW).

As stated before, the record is devoid of these teams rosters.  We can surmise that Eff this Ish has conceded the current season by making this deal as Machado does represent a slight downgrade at third base compared to Longoria.  However, Machado could be a strong keeper candidate for Eff this Fish as he is young third baseman who has already had success at the big league level.  Another valuable asset they acquired in this deal is getting a 5th round pick in the 2015 draft.  Draft picks in subsequent seasons are assets commonly bartered in keeper leagues.  See Bald Eagles vs. Weasel D, 3 F.J. 205, 208 (November 2011).  This pick will likely help Eff this Fish rebuild his team for 2015 and beyond.

Longoria has admittedly had a poor season thus far compiling only a .256 batting average with 12 home runs, 54 RBI, 55 runs scored and four stolen bases.  In comparison, Machado is batting .269 with 11 home runs, 28 RBI, 34 runs scored and two stolen bases while playing in over 30 less games than Longoria.  Machado is five years younger than Longoria, so he does provide long-term value for Eff this Ish.  It is apparent that they represent equitable compensation for each other.

We can then look at the exchange of Jose Altuve for Billy Butler.  This appears to be well in favor of the Ultimate HigWarriors who acquired one of the premier second baseman in fantasy baseball in Altuve.  Despite his small stature, the Astros’ All Star second baseman provides tremendous production in runs scored, stolen bases, and on base percentage.  In comparison, Billy Butler is a shell of his former self and has been unable to replicate his power or run production from the past several years.

Typically the only circumstances where a trade should be rejected are: 1) if the deal is made in violation of league rules; 2) if the deal is made through collusion; 3) the deal is so grossly lopsided that is has a detrimental effect on the whole league; and 4) if the deal makes absolutely no sense and/or fails to improve at least one of the team’s rosters in any capacity.  Grand Theft Votto vs. That Wimpy Deer, 6 F.J. 39, 42 (April 2014).  We do not believe this trade falls within the confined of any of those scenarios.  Eff this Ish is looking to rebuild his team in 2015, so the acquisition of a 5th round draft pick will aid him in that goal.  Even though the trade is slightly inequitable based on present day value, it still comports with the dichotomy of keeper league trade strategy.  Based on the foregoing, the trade between the Ultimate HigWarriors and Eff this Fish should have been approved.

IT IS SO ORDERED.

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