Clay Davis Youth League vs. League Commissioners – 6 F.J. 555 (September 30, 2014) – Fantasy Football Rule Dispute (Adrian Peterson)

SUPREME COURT OF FANTASY JUDGMENT

Clay Davis Youth League vs. League Commissioners

ON PETITION FOR WRIT OF CERTIORARI FROM
THE GURU’S FANTASY FOOTBALL LEAGUE

Decided September 30, 2014
Cite as 6 F.J. 555 (September 2014)

Factual Background

A fantasy football league called the Guru’s Fantasy Football League (hereinafter referred to as “GFFL”) is a 12-team PPR keeper league hosted on RTSports.com.  Every year, each team may select up to three (3) players to keep who were not drafted in the 1st or 2nd round the previous season.  For each player retained, owners must give up the draft pick two rounds better than the player chosen to be kept.

The GFFL’s rules regarding roster composition mandate that there are 17 players per roster with two Injured Reserve (“IR”) spots permitted per team.  The following provision in the GFFL’s rules specifically addresses the IR position:

MISC

Suspended players are not allowed on IR.  Only players that are OUT may be put on IR.

At 11:30 AM on Saturday, September 27, 2014, the team known as Clay Davis Youth League (hereinafter referred to as “CDYL”) moved Adrian Peterson (RB-MIN) from his active roster to one of his available IR slots.  CDYL made a corresponding transaction by adding Mohammed Sanu (WR-CIN).

At 11:42 AM on Sunday, September 28, 2014, CDYL received a text message from one of the league’s commissioners informing him that moving Adrian Peterson to IR was impermissible and that the transaction would have to be reversed.  CDYL sought to appeal this matter within the league, and the decision was upheld by both commissioners on Monday, September 29, 2014.  One of the commissioners justified the decision by stating that “AP has to come off the IR.  We don’t allow suspended players on it.”

Procedural History

The GFFL commissioners have denied CDYL’s appeal in this matter and will not permit Adrian Peterson to be placed on IR.  CDYL has submitted this subsequent appeal to the Court seeking a reversal of the commissioners’ decision and allowing Peterson to be placed on IR.

Issue Presented

(1)   Should CDYL be allowed to place Adrian Peterson on IR within the context of the league’s rules?

Decision

The GFFL is governed by a written set of rules in conjunction with the internal settings of the league.  It is common knowledge that we strongly advocate for 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).

To be fair, the rules of the GFFL were created, generated and distributed prior to the start of the NFL season.  Since that time, there have been multiple instances where players have gotten in trouble with the law which led to unique methods of handling by the NFL and individual teams.  As such, we can assume that the GFFL commissioners did not contemplate the status of players like Ray Rice, Adrian Peterson, Justin Dwyer and Greg Hardy when crafting the language of the rule regarding the IR slots.  After all, 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).

That being said, we can still look at the rule as it is written and interpret what its intent is and how it was meant to be applied.  As important as it is to follow the language of the league’s 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 rule in question is as follows: Suspended players are not allowed on IR.  Only players that are OUT may be put on IR.  Clearly there is consideration given to suspended players which makes sense since so many have tested positive for drugs, PED’s, banned substances, alcohol abuse, DUI, etc.  In most cases, these players that are suspended are only out for a finite period of time and will become active once their suspension is served.  As such, we understand the intent of the commissioners to not allow suspended players to be utilized on IR.

It seems apparent that the IR spots were intended to house injured players who have been either placed on NFL’s IR or are deemed OUT for a game due to health reasons.  When looking at the weekly injury reports, players labeled as OUT will not be active for that week’s upcoming game.  This is presumably one of the circumstances where a GM in the GFFL could place such a player on IR in exchange for adding a free agent.  The Court further assumes that if the player ruled OUT for that week is active the following week, a corresponding roster move would need to be made.  However, that is not specifically addressed in the league’s rules.  Furthermore, another scenario where the IR spot would be utilized is if a player sustains a season-ending injury and is placed on IR for the rest of the season, then he could be kept in an IR spot and still be available to be kept for the following season.  Again, the GFFL’s rules are not clear on this.

The fact we have to make assumptions and presumptions about scenarios where this rule is applied demonstrates how vague and ambiguous it is.  Even something as simple and mundane about prohibiting suspended players from being placed on IR can and should have much more specificity and detail within the context of the rule.  See The Great One, et al. vs. Tremendous Franchise, 5 F.J. 278 (November 2013) (holding that the league’s directive requiring owners to submit a valid starting lineup each week was vague and ambiguous because a “valid starting lineup” was not defined and there are viable reasons why a GM might not fill all starting roster slots).

The only factual conclusion we can draw from the language of this rule is that the league does not want to permit suspended players from being put on the IR.  However, it is unclear how the league’s rules would define Adrian Peterson in this context.  Players that have been or are currently suspended such as Josh Gordon, Matt Prater, and Wes Welker were officially docked pay for the games they were suspended.  In contrast, Adrian Peterson has been placed on the NFL’s exempt list but is still getting paid by the Minnesota Vikings.  Technically, he is not suspended.

The GFFL’s rule in question is vague and ambiguous for the purposes of determining whether Peterson can be placed on IR.  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); see also Pelham Bay Keeper League vs. Squatch’s Squad, 6 F.J 447, 449 (July 2014) (holding that a rule which allows a league committee to intervene and adjust a team’s lineup should not be invoked because it is vague and unclear about what specific circumstances such power is afforded).

If the GFFL commissioners intended on preventing players who were inactive for reasons other than health and injuries from being placed on IR, they failed to encompass all potential scenarios.  Because Peterson is technically not suspended, CDYL did not violate any rules and cleverly took advantage of such vague language.  See Pissy In Your Brown Eye vs. League Commissioner, 6 F.J. 491, 493 (August 2014) (holding that a GM should be permitted to keep  Reggie Wayne after adding him as a free agent in 2013 and subsequently placing him on IR as his actions were legal within the context of the written rules at the time).

Again, this is not to assign blame or fault to the commissioners who crafted the language of the rules.  We recognize the uniqueness of the situation.  However, the rules of the league must be implemented, followed and enforced as they are currently written.  The rule in question prevents suspended players from being placed on IR.  At the same time, Adrian Peterson is not a suspended player.  Therefore, the Court reverses the GFFL commissioners’ decision and rules that Peterson should be placed on CDYL’s IR and Mohammed Sanu should be added back onto his roster.  We recommend revising and modifying this rule in the offseason as rules should not be changed or amended during the course of a season barring unforeseen extenuating circumstances – none of which apply here.

IT IS SO ORDERED.

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