Get Roehled vs. League Commissioner – 6 F.J. 521 (August 21, 2014) – Fantasy Football Dispute (Keeper Deadline)

SUPREME COURT OF FANTASY JUDGMENT

Get Roehled vs. League Commissioner

ON PETITION FOR WRIT OF CERTIORARI FROM
THE OLD BALLS FANTASY FOOTBALL LEAGUE

Decided August 21, 2014
Cite as 6 F.J. 521 (August 2014)

Factual Background

A fantasy football league called the Old Balls Fantasy Football League (hereinafter referred to as “OBFFL”) is an 8-team standard keeper league created in 2009 and hosted on ESPN.  Every year, each team may select one player to keep and then that GM. loses the draft pick in the next earliest round in which that player was drafted in the previous season.

On August 3, 2014, the OBFFL commissioner sent out an email with the subject “OBFFL 2014 Kickoff” that outlined the details about the league including the keeper deadline being set for Sunday, August 17, 2014.  The appellant, Get Roehled, selected his keeper prior to that deadline.

On Tuesday August 19, 2014, Get Roehled checked the league’s website and noticed that only he and one other team had selected their keepers. He immediately alerted the OBFFL commissioner of this as the commissioner had not selected his own keeper either. The commissioner’s response was to change the league settings on ESPN and extend the keeper deadline to August 27, 2014.  Teams that hadn’t selected their keepers are now doing so in conformance with the amended deadline.

Procedural History

The OBFFL is bound by an unwritten set of rules known as “The By-Laws That Don’t Exist” which governs any and all actions of the league.  The appellant alleges that the actions of the commissioner by changing the keeper deadline are an abuse of power in violation of these unwritten rules.

Issue Presented

(1)   Should owners who did not select keepers prior to the original deadline be allowed to do so subsequent to the commissioner extending the deadline?

Decision

The issue presented to the Court is of paramount importance because it has major implications on the league’s draft.  The draft is truly the cornerstone of any fantasy league and should be treated with sanctity, fairness, and equity.  See Pissy In Your Brown Eye vs. League Commissioner, 6 F.J. 491 (August 2014).  It is imperative that any decisions made surrounding the draft be intelligent, objective, and for the benefit of the entire league because this is where people create and build their teams.  See Mayor Goldie Wilson vs. Balloon Knots, 3 F.J. 164, 166 (September 2011).

The crux of this case is determining whether a commissioner’s alleged abuse of power truly caused damage to the appellant and/or the league overall.  Given the facts of this case, we must conclude that the OBFFL commissioner did in fact take advantage of his power by changing the deadline by which keepers were to be declared.  But we must determine whether such actions are reversible and what potential damage was caused to warrant any such intervention.

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).  The OBFFL is not governed by a written constitution or set of rules.  Rather, the league appears to be governed by an unwritten set of rules which we cannot grant any authority to.  The Court strongly advocates for fantasy sports league commissioners to have a written constitution or set of rules that govern their leagues.  See John Doe vs. Fantasy Football League Commissioner, 2 F.J. 21, 22 (October 2010).  One of the primary reasons is so that all league members are aware of the rules and have access to them at any time.  This provides actual notice of the rules to all members of the league and shifts the burden onto them to comply.  Shawn Kemp is My Daddy vs. Fantasy Basketball League Commissioner, 2 F.J. 24, 25 (October 2010).   Any questions or challenges to such rules should be addressed as soon as practicable.  See Machine vs. Fantasy Football League Commissioner, 2 F.J. 1, 2 (September 2010).

Despite not having a formal constitution or written set of rules, the fact remains that the guidelines of the league were laid out in an email from the commissioner as well as entered into the OBFFL’s website on ESPN.  The appellant provided evidence which proves that the commissioner informed the league on August 3, 2014 that the deadline to declare keepers was August 17, 2014.  There is also evidence which has been submitted which shows the league settings were changed on August 19, 2014 to reflect continuing the keeper deadline until August 27, 2014.

We cannot speculate as to why or how the commissioner and five other league members did not declare their keepers by the August 17, 2014 deadline.  But once the commissioner’s email went out and the league’s website was updated with information for the 2014 season, then the GM’s are on direct notice and should be responsible for doing their due diligence when managing their teams and navigating the league’s website.  The Rams vs. Anger Management, 4 F.J. 267 (October 2012) (holding that a team cannot revoke a trade that was agreed to and approved on the league website merely because he mixed up a player with the same last name).

The commissioner was clearly lax in monitoring and enforcing the deadline that he presumably set.  In fact, he did not even select his own keeper by that date.  The appellant was well within his rights to alert the commissioner of this issue.  Romophobia vs. The Waterboyz, 4 F.J. 216, 218 (August 2012) (holding that commissioners should have a reasonable expectation that their fellow league members will alert them of any possible issues in a timely manner).

It is entirely possible that when the commissioner renewed the league on ESPN that August 17, 2014 was a default date selected automatically.  However, he confirmed it in an email.  If he had an intention of changing the date, he certainly never took proactive steps to inform anyone of such a decision.  Typically the Court will uphold a commissioner’s decision so long as it is in the best interests of the league overall and absent any self-serving motivation.  Fair and Balanced vs. League Commissioner, 5 F.J. 1, 2 (January 2013).  The problem in this case is that the commissioner’s decision was completely self-serving since he blew the deadline himself.  If the original deadline was enforced, then the commissioner would not have been able to keep a player on his own team.  This clearly created a conflict of interest.

The Court is frequently presented with appeals of a commissioner’s inherent power to enact, enforce, and modify rules within the league without any challenge to his authority.  Typically, the Court will affirm a commissioner’s decision assuming his motives are in the best interests of the league overall.  See Afraid of Change vs. Fantasy Football League, 1 F.J. 11, 12 (September 2009); see also Parts Unknown vs. League Commissioner, 5 F.J. 8 (February 2013) (holding that a commissioner has the authority to change the league’s roto categories if he believes it will improve the overall function of the league and is in everyone’s best interests).  But when the commissioner has a vested interest in his own decision-making, it creates a significant problem which is at the heart of this issue.

The Court truly sees no harm in having the keeper deadline extended so all teams can select their individual keeper player before the draft.  There is no damage or prejudice caused to any teams so long as the keepers are selected prior to draft day.  But just because there is no damage or prejudice based on the end result, it does not absolve the commissioner of responsibility for his actions.

We understand why the appellant is upset at these actions.  He abided by the rules as they were provided and available, and now he is witnessing six other GM’s who did not follow the rules yet are still being granted the same luxury as him by getting to keep one player.  There was an expectation that each team would select one keeper player who would not be eligible for the draft.  Since it appeared that six other teams had not set their keepers on time, it created a scenario where the appellant could have drafted a player that otherwise would have been kept.

Instead, the commissioner arbitrarily extended the deadline so that he and the other five offending teams could still set their keepers.  We don’t necessarily have a problem with the actual continuance of the deadline because the intention of the rule is for all teams to declare their keepers so long as it happens before the draft.  The problem that pervades this case is the actions of the commissioner unilaterally making this decision for which he is a direct beneficiary.  This creates a conflict and could potentially undermine the credibility of the commissioner for putting his own needs ahead of the league.

It would be one thing if only one team, or even only the commissioner, had failed to declare a keeper by August 17, 2014.  That would lead to an easy conclusion that only one team made the mistake and was not an epidemic.  But what we have here is 75% of the league failing to adhere to a deadline.  That is problematic and likely needed to be rectified.  There are no excuses to give by any team for missing the deadline since they were afforded over two weeks’ notice of the August 17, 2014 end date.  But the fact that five other GM’s besides the commissioner neglected to set their keepers helps diminish the self-serving nature of his decision.

The Court recommends that the commissioner enforce all rules and guidelines consistently.  If the commissioner makes an exception for someone, it should be explained thoroughly why such an exception to the rules exist.  See Machine vs. Fantasy Football League Commissioner, 2 F.J. 1, 3 (September 2010).  It doesn’t appear this was done, so we would suggest the commissioner explain to the entire league why he himself missed the deadline and whether it was the initial intent to have August 17, 2014 be the final day to declare keepers.

Remember, there is no written constitution or charter in place.  Without a league constitution, commissioners are essentially free to create and change rules autonomously, within reason,  unless there is some sort of agreement in place where each league member votes on rule changes or decisions.  See Didn’t Hit Submit vs. Commissioner, 1 F.J. 23, 25 (January 2010).  Commissioners do have the final say on issues that are outside the purview of the internal league functions of the host website.  See Dwayne Bowe Peep vs. The Boston Tea Party, 3 F.J. 188, 190 (October 2011).

When looking at this issue in its totality, we conclude the commissioner’s actions in extended the deadline for declaration of keepers should be upheld.  While he did further a self-serving purpose, the fact remains that he and five other people did not declare their keepers by the 17th and this represents 75% of the league.  So when comparing self-servings interests with the best interests of the league, we are left with a conclusion that this decision was made on behalf of almost the entire league.  Plus, because the draft hasn’t taken place yet there is no tangible harm or damage done to Get Roehled who actually did follow the initial instructions and deadline.

  The way this should have been handled is that the commissioner should have reached out to the entire league when he was made away that he and five other GM’s didn’t select keepers by the deadline.  He should have addressed what the rule was from his initial email and on the league website and followed that up with an honest mea culpa accepting responsibility for the failure to adhere to his own rules.  That being said, he should have proposed an extension of the deadline allowing the offending teams the opportunity to declare their keepers while also affording Get Roehled the chance to change his keeper selection (if he so desired) by the new deadline.  The commissioner also should have offered to formally codify a set of rules into a document and created a process by which internal disputes can be handled, especially if the commissioner’s own team was involved.

IT IS SO ORDERED.

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