WOW League vs. Eagles, at al. – 6 F.J. 577 (October 29, 2014) – Fantasy Football Dispute (No Penalty for Rule Violation)

SUPREME COURT OF FANTASY JUDGMENT

WOW League vs. Eagles, et al.

ON PETITION FOR WRIT OF CERTIORARI FROM
THE WOW LEAGUE

Decided October 29, 2014
Cite as 6 F.J. 577 (October 2014)

Factual Background

A fantasy football league called the WOW League (hereinafter referred to as “WOW”) is hosted on Yahoo and utilizes an auction format for its draft with a $200.00 budget given to each manager.  Each team has 16 roster spots plus one additional injured reserve (“IR”) slot.

WOW also has custom rules that must be applied manually over and above what Yahoo’s settings are capable of enforcing. Each manager has 20 contract years to apply towards their 16 players. Each player must be signed to at least one contract year with the option to distribute the remaining four years to rostered players in order to keep them in future seasons.  The following are some of WOW’s rules that are relevant to this case:

  • At no point in the year is a manager allowed to go over 20 years in total contracts. For example, a manager cannot trade for a player signed to a multi-year deal that would put him/her over the 20 year limit.
  • Waivers are done using a Free Agent Acquisition Budget (FAAB) of $100.
  • Managers can sign FA’s/Waivers to multi-year deals granted they have enough years left to spend. They do so by posting on the league message boards immediately after signing said a player. If they do not post, it is assumed they are signing that player to a 1 year deal.
  • If an IR eligible player (designated by Yahoo!) is put in the IR slot, their years come off his/her manager’s 20-year limit.

It should be noted that there is no penalty specified in the league’s rules for going over the 20 year limit on contracts.

On October 7, 2014, the WOW commissioner, in his capacity as owner of the team known as the Eagles, traded Julius Thomas (TE-DEN on a 1-year deal) and Odell Beckham, Jr. (WR-NYG on a 1-year deal) to Beats by Ray in exchange for Vincent Jackson (WR-TB on a 2-year deal) and DeAndre Hopkins (WR-HOU on a 1-year deal).  This trade put the Eagles over the 20-year contract limit for a total of 21 years, and conversely it lowered Beats by Ray down to 18 years.  At the time of the trade, neither party realized that Vincent Jackson was signed to a 2-year deal and the trade was allowed to go through.

On October 11, 2014, the Eagles turned around and traded Vincent Jackson (2-year deal) to Duffy’s Dusters for Ben Tate (RB-CLE on a 1-year deal).  This trade put the Eagles back down to a legal 20 contract years and Duffy’s Dusters increased their total from 19 years to 20 contract years.

This illegal trade was discovered on October 26, 2014 at which point the Commissioner, as one of the offending parties, compiled several punishment options and advised the league they can vote to choose one of the options or present their own option for a punishment. The below are the options/opinions of the league:

  1. All of the players that were illegally rostered (Vincent Jackson, Julius Thomas, DeAndre Hopkins, Ben Tate & Odell Beckham Jr.) should have their contracts voided and be dropped.
  1. Eagles, Duffy’s Dusters and Beats by Ray should receive automatic losses for the previous three weeks, but the illegally acquired players remain on their current rosters.
  1. Only the Eagles (commissioner) should be punished because neither Duffy’s Dusters nor Beats by Ray violated the 20-year limit by making these trades.
  1. A $25.00 cap penalty in next year’s draft is assessed against all three managers.
  1. A $25.00 cap penalty in next year’s draft is assessed against the Eagles only.
  1. A $25.00 cap penalty in next year’s draft is assessed against the Eagles smaller penalties (if at all) are assessed against Beats by Ray and Duffy’s Dusters.
  1. The trades should all be reversed and some form of additional punishment should be levied on against the Eagles or all three managers.
  1. Any combination of the above options.

In addition, a league member known as MMD argues that precedent for this type of issue was established on October 25, 2014 when the WOW commissioner (Eagles) ruled that one of MMD’s contracts was void as a result of going over the 20-year limit. On October 22, 2014, MMD picked up Victor Cruz (WR-NYG) off of waivers for $2.00 and was designated as IR eligible by Yahoo.

Before picking up Cruz, MMD had 15 players rostered for a total of 20 contract years.  MMD had dropped a player earlier in the year and decided to only carry 15 players on his roster instead of 16 in order to fit in a player on a multi-year deal.  As a result of only carrying 15 players, Yahoo allowed him to pick up Cruz without dropping a player.  MMD then placed Cruz into his IR slot and posted on the message boards that he was signing him to a 2-year contract. After a manager complained, the commissioner ruled that this contract was void.

The basis for the commissioner’s decision was:

  1. By picking up Cruz without dropping a player, MMD went over 20 years momentarily between the time of the acquisition and the time he placed Cruz on his IR slot (the contract years for players in the IR slot do not count against the 20-year limit). Since no one outbid MMD at the time of the waiver pickup, the commissioner allowed MMD to drop Ryan Mallet (QB-HOU) four hours after the waiver bids went through on October 22, 2014 to retroactively make it a legal acquisition.
  1. After further review of the rules, it was determined that MMD in fact needed to drop two players in order to sign Cruz to a 2-year deal. This double infraction in which MMD went over 20 years during the period between the time of pick-up and placing Cruz in the IR slot was enough to allow the commissioner to rule that the Cruz’s contract should be void and MMD would forfeit the $2.00 he spent on Cruz.
  1. MMD dropped Cruz before the commissioner’s official ruling was disseminated. The commissioner offered to put Mallett onto his roster, but he declined.

After this issue with Victor Cruz came to light, the ninth potential remedy to come out of this situation is if the traded players remain on their current rosters, then MMD’s contract for Cruz should not be void and he should be added back to MMD’s roster.

Procedural History

The WOW commissioner has submitted this case to the Court seeking a ruling on whether a penalty should be enforced against some, all or none of the teams who may have broken the 20 contract years rule outlined in WOW’s constitution. The constitution does not specify a penalty for this infraction, and as a result the league and its members are unsure of a sufficient punishment that should be levied based on the interpretation of the rules.  Furthermore, the commissioner is one of the league members who have broken the rules.  In an attempt to maintain impartiality in the decision-making process, he left the decision on penalties open to a league vote.  A variety of options were brought forward with no consolidated decision finalized.

MMD now argues that precedent was set in terms of punishment for going over a 20-year limit. He argues that if a decision on a punishment is made which allows Eagles, Duffy’s Dusters or Beats by Ray to keep the players they traded for, then he should be allowed to keep Cruz.   Alternatively, similar punishment (namely, a void contract) should be applied to the parties that broke the rules.

Issue Presented

(1)        What, if any, punishment should be enforced against the Eagles and/or Beats by Ray and/or Duffy’s Dusters for violating the rules regarding contract years?

(2)        Should MMD be entitled to keep Victor Cruz on his roster after adding him and placing him on IR?

Decision

I.     WHAT, IF ANY, PUNISHMENT SHOULD BE ENFORCED AGAINST THE EAGLES AND/OR BEATS BY RAY AND/OR DUFFY’S DUSTERS FOR VIOLATING THE      RULES REGARDING CONTRACT YEARS?

The Court strongly advocates for fantasy sports 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).

While we commend the WOW league for having a constitution, it was incomplete insofar as there are rules in place which do not have corresponding penalties for infractions.  This responsibility falls squarely on the commissioner who is 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).  It is a commissioner’s responsibility to oversee the administration of the league to ensure that all rules are being complied with by its league members.  That being said, each and every league member also a duty to report any known infractions as soon as they are discovered.  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).

The fact that it took several weeks for the issue of the Eagles’ exceeding the allotted number of contract years is troubling.  The fact that it was the commissioner himself that violated the rules and was seemingly unaware is problematic.  It should be noted that there are no allegations of abuse of power or any type of intentional malfeasance.  As such, we do not need to engage into an analysis of a commissioner taking advantage of his authority.  But we still must hold the commissioner to a higher standard merely because of the position he has and the responsibilities attached to having such authority.

There was an existing rule in place which restricts the number of contract years allotted to each team.  This indicates it was an important enough issue that should have been closely monitored every time a transaction was made, whether it is a waiver wire acquisition or a trade between teams.  Clearly the commissioner failed to act accordingly when his own trade put him in violation of the rule.

In terms of responsibility for Beats by Ray and Duffy’s Dusters, it could be argued that they had a duty to ensure their trades were made in accordance with the rules.  But from their perspectives, the trades did not result in any violations on their behalf.  To expect them to investigate and ensure that their trade partners remained in compliance is not reasonable.  That is what the commissioner is there for in terms of enforcing the applicable rules.  As such, we conclude that there should not be any penalty enforced on Beats by Ray or Duffy’s Dusters.

The analysis now focuses on what, if anything, should be done with respect to the commissioner’s violation of the rules.  We must first address the legal concept of “fruit of the poisonous tree.”   It is a principle which stands for the premise that if the source of evidence is tainted, then anything gained from it is tainted as well.  It could be argued that the initial acquisition of Vincent Jackson was tainted because it put the Eagles over their allotted 20 contract years.  As such, any further trades made subsequent to that initial deal are tainted as well.  However, when determining what consequences should be enforced we must consider the overall best interests of the entire league.  This requires a balancing of the harm done compared to the potential penalty enforced.

The subject trades that are allegedly tainted were fair and equitable.  Had they been submitted to the Court for review, we have no doubt they would have passed muster and been approved based on the merits of the deals.  Typically the only circumstances where we will reject a trade 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).  Had the initial trade been submitted to the Court, we would have had authority to reject it based on it violating the rules of the league.  But that did not happen so we must accept the timeline of events as they transpired.

The methods of punishment proposed and suggested by the WOW league members were well thought out and crafted reasonably.  But the problem is that enforcing any of these penalties, or other options not listed, would result in a more serious intervention to undermine the integrity of the league.  That is because the league’s rules are devoid of any penalties or punishments for violations and infractions.  This is directly on point with Cannon’s Cripples vs. Hollifield’s Heroes which held that it would be against public policy to penalize a violation of one of the transactions rules when no penalty is delineated in the rules.  Cannon’s Cripples vs. Hollifield’s Heroes, 5 F.J. 301, 304 (December 2013)  5 F.J. 301, 304 (December 2013).  If a rule is written prohibiting a specific action, there should be corresponding penalties and punishments delineated for violation of such a rule to make it enforceable.

This is not to say that there cannot be some consequence going forward, especially if the commissioner is willing to accept responsibility.  But we strongly discourage the league from retroactively changing the results of prior games or even undoing transactions that have been made which would otherwise be acceptable.  We have consistently held that game results, standings, and prize money should never be modified, overturned or changed unless there was an obvious scoring mistake by a stat server or proof of teams cheating or colluding.  See Tenacious Muckers vs. Team WeeWee, 5 F.J. 297 (December 2013) (citing Didn’t Hit Submit vs. Commissioner, 1 F.J. 23, 27 (January 2010)).  There is no indication of any scoring discrepancy by Yahoo, nor are there any allegations of cheating or collusion.  Rather, the allegation is that the commissioner himself violated the rule regarding maximum contract years.  .

We acknowledge that the chain of events never should have gone as far as they did, and ultimately players were traded in deals that would not have materialized in the same manner in which they did.  But the technical violation of the rule did not prejudice any other team since the deals were fair and equitable in nature.  It would be even more prejudicial to the entire league to retroactively adjust the results of games or remove players from GM’s rosters when they were not in violation of the rules to begin with.

The conclusive aspect of this decision is premised on the fact that there are no penalties in place for having violations to the rules.  As such, we hold that the game results of the past three weeks since the infraction took place should not be adjusted or changed.  In addition, we would not recommend dropping the players from these teams’ rosters or placing them back to their original owners.  Doing either of these would create more complex issues to be dealt with and could perpetuate the problem unnecessarily.

We strongly recommend that the league’s rules be amended in the off-season to include specific penalties and procedures to be enforced when a rule such as this is violated.  In addition, the league should consider whether to amend the rule itself to allow a specific limited time frame where a GM must adjust his roster if a transaction is made that causes someone to exceed 20 contract years (i.e., a GM must make a corresponding transaction within one hour of being over the limit).  This is merely a suggestion in the event the league wants to consider being more flexible to avoid scenarios like this in the future.  We would also recommend that the commissioner appoint a co-commissioner who can be solely responsible for reviewing all transactions made during the season to ensure that all teams remain in compliance with the contract year requirements.  This way it can be immediately determined whether there is a violation, and if so, the transaction can be undone or addressed without any further tainting.

In terms of what repercussions should be placed against the commissioner, we recommend a penalty be enforced against his own team in 2015 whether it be a percentage of his salary cap budget be garnished (i.e., what was initially suggested as a $25.00 reduction) or to reduce his allotment of contract years from 20 down to 19.  This does not appear to be an intentional act or an abuse of power, so we must be reasonable in assessing what punishment should be in place.  Even though the penalty would not be enforced during the year of the infraction, it could serve as a deterrent for future violations.

II.     SHOULD MMD BE ENTITLED TO KEEP VICTOR CRUZ ON HIS ROSTER AFTER ADDING HIM AND PLACING HIM ON IR?

In order to maintain consistency, the handling of the previous scenario should carry over to how the situation with Victor Cruz and MMD is handled.  Granted, there are no subsequent issues that follow with the addition of Cruz since he is out for the season and will not accumulate any more points for the year.  But again, there was no penalty delineated in the rules to address how to handle a situation when a GM exceeds his allotted 20 contract years.  The commissioner made an independent decision to remove Cruz from MMD’s roster because he was over the limit in between the time Cruz was added and then placed on IR.

It would be less problematic to remove Cruz from MMD’s roster because no further transactions followed.  But that would be contradictory to the recommended course of action to take with the commissioner’s own infraction of the rule.  MMD did rectify the violation by dropping players from his roster and there was no prejudice to anyone else since MMD won the rights to Cruz by bidding on him in FAAB.  We understand that perhaps another team could have bid on him later in the season with the same plan as MMD.  However, that is pure conjecture and speculation.  We must adhere to consistency and fairness for the entire league, and the only way to do that is to treat these two situations similarly.  As such, we hold that Cruz should remain on MMD’s roster and any necessary transactions to reduce his contract years down to 20 should be made immediately.  In addition, we recommend enforcing a similar but proportionate penalty against MMD in 2015 such as a $2.00 garnishment of his salary cap budget and/or a reduction of his allotted contract years from 20 down to 19.  This way, MMD does not receive an entire windfall for his violation of the rule.

IT IS SO ORDERED.

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