Team Bundy vs. League Commissioner – 5 F.J. 67 (June 4, 2013) – Fantasy Baseball Dispute (Commissioner’s Abuse of Power)


Team Bundy vs. League Commissioner


Decided June 4, 2013
Cite as 5 F.J. 67 (June 2013)

Factual Background

An anonymous rotisserie fantasy baseball league (hereinafter referred to as “the league”) contains 12 teams and is a mixed AL/NL non-keeper league.  The league uses the standard 5×5 scoring categories to determine the standings and prize money.  For offensive players, the five categories are: (1) batting average; (2) homeruns; (3) runs batted in; (4) runs scored; and (5) stolen bases.  For pitchers, the five categories are: (1) wins; (2) earned run average; (3) WHIP (walks+hits/innings pitched); (4) strikeouts; and (5) saves.  Statistics are cumulative throughout the course of the season and there are no head to head games contained within the league.

It is unknown whether the league is governed by a written constitution or set of rules.  It has been disclosed that the league utilizes an auction bidding process to determine free agent and waiver wire claims.  The league’s auction is set to run every Monday and Thursday at 2:59 AM.  Only the commissioner has the ability to enter transactions or change the waiver results after the bidding process has been completed.

On Monday, June 3, 2013, league members were able to view the list of all of the transactions made during the previous night’s auction.  Team Bundy, one of the teams in the league, noticed that there was a transaction made at 10:04 AM on June 3, 2013 where the commissioner’s team added Ike Davis (1B-NYM) and dropped Dustin Ackley (2B-SEA).

Procedural History

Team Bundy brought this to the league’s attention via their message board and criticized the commissioner for abusing his power to enter transactions after the auction was completed.  The commissioner responded by saying that his actions had no detrimental effect on the league since no other team claimed Davis and he simply forgot to put a bid in for him the previous night.

Team Bundy submitted this case seeking intervention from the Court to revoke the commissioner’s transaction and reprimand his abuse of discretion.

Issue Presented

(1)        Should the commissioner’s post-auction transaction be revoked?


The Court takes this issue presented extremely seriously because any alleged abuse of discretion by a commissioner jeopardizes the integrity of the entire league.  There is no question that being a league commissioner is a thankless job filled with additional stress and pressure on top of trying to compete within the league itself.  See A-Holes & Pujols vs. Mad Cow Disease, 3 F.J. 44, 46 (June 2011) (holding that a commissioner is also entitled to manage his team to the best of his ability and try to win); Johnny Bench’s Baseball Bunch vs. Yuniesky Betancourt’s Revenge, 4 F.J. 13 (February 2012) (holding that a commissioner’s acquisition of free agents during his league’s playoffs should be upheld because he complied with the long-standing rules).  However, those that choose to take such responsibilities must do so in good faith to serve the best interests of the league overall.

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).  Not only must commissioners then enforce those rules, but they must abide by them as well.  Here, the commissioner is also a member of the league so he is subject to the same rules and procedures as everyone else.  But, along with great power comes great responsibility to avoid abusing such power.

Whether there are written rules or not, there is a generally accepted code of conduct within the fantasy sports industry 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).  That code of conduct includes commissioners as well.

The Court is frequently presented with challenges to a commissioner’s decision as well as his inherent decision-making power.  Typically the Court will uphold a commissioner’s decision or actions so long as it is in the best interests of the league and absent any self-serving motivation.  Fair and Balanced vs. League Commissioner, 5 F.J. 1, 2 (January 2013).  Unfortunately, this case is wrought with self-serving motivation and goes completely against the best interests of the league.

Generally, rules and guidelines should be enforced consistently unless there is a justification to create an exception.  Any exception made to an existing rule should be corroborated by a thorough explanation by the commissioner.  See Machine vs. Fantasy Football League Commissioner, 2 F.J. 1, 3 (September 2010).  This is especially true if the exception being made is for the benefit of the commissioner himself.

In this case, the commissioner was either completely oblivious or deliberately indifferent to the possible reaction by his fellow league members towards his actions.  This is disturbing because commissioners are understandably under more scrutiny than the other members of the league simply because of the power and authority that they possess.  As such, commissioners should be cognizant of how their actions will be perceived by others.  Because the league commissioner completely dismissed Team Bundy’s dissent and did not consider any ramifications for his own actions, the Court can easily conclude that he did not consider what is best for the league overall.  See America’s Team vs. The 1987 Denver Broncos are Cartman’s Father, 3 F.J. 51, 53 (July 2011) (holding that a league commissioner’s credibility is endangered when he steadfastly refuses to consider logical and meritorious complaints).

The Court will not hesitate to uphold a commissioner’s actions when they are made within the scope of his autonomy and discretion.  However, certain things cross that line of demarcation when such actions morph into a complete abuse of power.  Cincinnati Bungles vs. O&A’s Two Point Conversion, 3 F.J. 88, 90 (July 2011).  In this case, it is clear that the commissioner has put his own interests ahead of the rest of the league.

When a commissioner takes advantage of his authority by accessing certain tools that no one else has, he creates an environment within the league that is ripe with bitterness, resentment, mistrust, and anger.  The free agent auction bidding process is automated by the league’s host provider.  It is set to run on the days that are scheduled – in this case on Monday and Thursday.  The auction runs on those nights at 2:59 AM.  Once the transactions are awarded, there is a log that is generated showing each team’s moves.  Lineup and roster transactions are also kept and time-stamped, available for anyone to access.  The commissioner should have known that his actions would be discoverable after he added Ike Davis seven hours after the auction ran.

There is precedent in this Court for enforcing the strict applicability of the FAAB settings.  In Green Eggs & Hamels vs. Megan Fox is Hot, the Court upheld the commissioner’s denial of an appeal by a league member who claimed that he should have been awarded a free agent because he placed a bid prior to another team that was ranked higher on the waiver priority order.  The Court held that the rules and settings for the FAAB process were clearly explained and implemented.  That is exactly what we have in the present case.  The only difference is that it was the commissioner circumventing the rules.  Based on the foregoing, the commissioner’s post-auction transaction should be nullified and Ike Davis should return to the free agent pool.  In addition, the commissioner should apologize to his fellow league members for such an abuse of power and ensure that this never happens again.


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