Pelham Bay Keeper League vs. Squatch’s Squad, et al. – 6 F.J. 511 (August 15, 2014) – Fantasy Baseball Dispute (Illegal Lineups)


Pelham Bay Keeper League vs. Squatch’s Squad, et al.


Decided August 15, 2014
Cite as 6 F.J. 511 (August 2014)

Factual Background

A head-to-head points-based fantasy baseball league called the Pelham Bay Keeper League (hereinafter referred to as “PBKL” was established in 2002 and is hosted on CBS. The PBKL is a 12-team daily mixed AL/NL keeper league where GM’s play against two other teams every week.

According to the PBKL commissioner’s recitation of league history, pitchers are almost never kept on the bench on days that they start. On a few rare occurrences, an owner has benched a pitcher based on a projected touch matchup against a specific opponent. The PBKL’s scoring system awards pitchers 20 points for a win, 15 points for a quality start, and significant points for a variety of other pitching statistics. In sum, pitching is more valuable than hitting in the PBKL and a majority of players that are kept from year to year are pitchers, including both starters and closers.

The PBKL has the following rules regarding lineups:

Rule 6.1

All owners have the responsibility of maintaining a legal lineup everyday when lineups set for the day (lineups set 5 minutes before first game of the day).

Rule 6.2

Illegal lineups after the All Star Break – (only applies to owners that are decided by the Commissioner Committee to be jeopardizing league integrity, whether it’s due to not paying attention or whatever reason). If that owner has an illegal lineup, the commissioner committee will contact that owner as soon as it is known to them to have the owner make their lineup legal. If, after contacting the owner, the lineup is not fixed or continues to be a problem, the committee will do what they feel is best for league integrity (Ex -make their lineup legal)

Squatch’s Squad is currently in last place and has allegedly kept starting pitchers on his bench on days that those pitchers are scheduled to start. Recent examples provided include keeping Alfredo Simon (SP-CIN) on the bench on August 9, 2014 and Tyson Ross (SP-SD) on the bench on August 10, 2014. This is on the heels of similar actions taken by Squatch’s Squad which was the subject of Pelham Bay Keeper League vs. Squatch’s Squad, 6 F.J. 447 (July 31, 2014) where the Court ruled that the commissioner committee should not take any action with respect to adjusting lineups and rosters. The Court further ruled that if Squatch’s Squad or any other team failed to field a complete and legal lineup, repeated emails should be sent with warnings that continued behavior will lead to possible suspension or expulsion from the league. In addition, immediate action under Rule 6.2 should only be reserved for extreme instances where a GM fails to set any lineup or there is proof that a GM is manipulating its lineup intentionally to affect the overall standings.

In addition to Squatch’s Squad, another team called Jock Itch (currently in 10th place) has recently kept two pitchers who were starting on his bench: Adam Wainwright (SP-STL) on August 7, 2014 and Chris Tillman (SP-BAL) on August 13, 2014.

Procedural History

The PBKL commissioner, along with multiple GM’s in the league, feel that Squatch’s Squad is purposely trying to tank the season in an attempt to finish in last place in order to get the first overall pick in the 2015 draft. The commissioner is also concerned that Squatch’s Squad and Jock Itch may by giving their two opponents each week undeserved victories which can damage the integrity of the league.   The commissioner and other league members are very concerned these GM’s actions will have a detrimental effect on the league over the next several weeks as multiple teams vie for the four available playoff spots.

Issues Presented

(1)        Is there any action the commissioner committee can take against Squatch’s Squad and Jock Itch for their ongoing offenses?

(2)        How should a rule be constructed to prevent GM’s from intentionally benching their pitchers on days they start?



Because the facts of this case and most of the parties involved are strikingly similar to the previous case, we hereby incorporate by reference the facts and holdings from Pelham Bay Keeper League vs. Squatch’s Squad, 6 F.J. 447 (July 31, 2014). As we previously held, Rule 6.2 is the governing provision on this issue, and the only recourse that is delineated in the rule happens to be vague. Taking action in order to do what is best for league integrity (such as utilizing commissioner privileges and access to make the offending team’s lineup legal) could create more problems now and in the future.

What is interesting is the suspicion that Squatch’s Squad is intentionally leaving these pitchers on his bench for the purpose of finishing in last place so he can secure the first pick in next year’s draft. That is relatively similar, but on the opposite end of the spectrum, to the facts of Awful Mitigators vs. Skeletors, 4 F.J. 316 (December 2012) where a team that clinched a playoff berth chose to take players out of his lineup on a Monday who were playing in that week’s Monday Night Football game. That GM reasoned that he did not want to accumulate any additional fantasy points because it would have elevated him to a higher seed in the playoffs and given him a less favorable matchup than he wanted. The Court ruled that if a GM has earned such a luxury, he is entitled to decide how competitive he chooses to be in a particular game in order to secure a desired playoff seeding.

In addition, The Great One, et al. vs. Tremendous Franchise, 5 F.J. 278 (November 2013) also provides a set of similar circumstances where a team that earned a playoff berth had the right to choose whether to field the most competitive lineup as possible. In this case, the appellee had also already earned a playoff berth and expressed his indifference as to whether he won or lost the remaining games of the regular season. The Court understood that some of the appellants could be affected by Tremendous’s decisions which could impact the outcome of some of his games. But that was of no concern to Tremendous. There was no evidence of collusive activity between Tremendous and any other team with respect to a quid pro quo of dumping games in exchange for something. As a result, the Court denied the appellant’s request for punitive action and intervention.

In this case, we have a team who is in last place and could be making conscious decisions to lose his games in order to secure an advantageous draft pick next year. The distinction between the prior two cases cited and the present case is that there were no requirements to have a legal lineup or any potential recourse if one was utilized. The PBKL does have a rule which requires owners to have legal lineups, especially after the All Star break. However, the PBKL fails to define what constitutes a legal lineup. We can surmise that an illegal lineup is one where there is an empty slot on a team’s starting lineup on any given day. Even if that is accurate, there is no definable penalty in place to deter GM’s from having illegal lineups. Rather, the only recourse is for the commissioner committee to remind the offending team of their actions or then possibly intervene and fix the lineup themselves.

We understand that if Squatch’s Squad sets out to lose his remaining games, it could have an effect on the standings by essentially awarding his opponents with victories. That is identical to the situations in both Awful Mitigators vs. Skeletors and The Great One, et al. vs. Tremendous Franchise. There have been no allegations made about potential collusive activity between Squatch’s Squad, Jock Itch, and any other team. If there were suspicions of collusion such as an exchange of financial interests or future trades with one of their opponents, then that would be an entirely different story. Instead, it appears that Squatch’s Squad is motivated by the lure of the first overall draft pick in 2015. That is a reasonable objective to have and certainly provides motivation for his actions.

Since we do not endorse the commissioner committee going in and manually altering any other team’s lineup, we cannot recommend that Rule 6.2 be implicated as written. As we held in the previous case involving these parties, the rule itself is vague and ambiguous which means we will interpret it in favor of the league member(s). But that does not mean the commissioner committee has to stand idly by while some teams either intentionally or unintentionally field less than competitive lineups. We would suggest implicating Rule 6.2 by telling the offending teams that they are required to field a legal lineup every day. The standards would be the bare minimum in that they could still choose to not start their better pitchers so long as all roster slots were filled every day (remember, the requirement is to field a legal lineup, not the best lineup). In the event there are any further infractions which do not appear to make sense from a practical competitive viewpoint, the commissioner committee shall consider punitive action against the offending GM’s including possible suspension or expulsion from league, or monetary fines or penalties enforced for next year’s league.


Unfortunately the Court cannot, in good faith, make a recommendation that a league employ a rule which requires or forces a GM to play certain players at specific times. This infringes on fantasy GM’s individual rights to manage their team according to their own preferences and strategies. It is not for the Court, the league, the commissioner, or anyone else to dictate who must be included in a team’s lineup on a day to day basis.

There are a myriad of reasons why a GM might not start a pitcher on a day he pitches. Some examples include a purported poor matchup against an opponent, personal rooting interest of the opposing MLB team, or to delay approaching a maximum innings limit. True, some other reasons could be to prevent accumulating points or to lessen one’s chances of winning for the reasons alleged against Squatch’s Squad. But unless there is some form of collusion in place where another GM is obtaining a tangible benefit as a result to an agreement made for such quid pro quo, the league should stay out of GM’s decision-making process when it comes to deciding who to include in the starting lineup.

We would suggest including a provision in the rules which requires good sportsmanship and good faith in the spirit of competition. The commissioner committee could retain the right to investigate whether a league member is violating the spirit of competition based on their alleged actions. However, in a case such as this, there appears to be a viable motive behind these roster decisions. But if the committee determined that this was not a valid motive, it could impose punitive measures against the team such as what we mentioned earlier – possible suspension, expulsion, or monetary fines and penalties. One typical method of recourse is to automatically disqualify a team for the week if they do not have a legal or valid lineup. However, if a team is seeking to intentionally lose, than this penalty only further serves their goals.

The concerns we had in the initial case involving Squatch’s Squad remain in place here. We understand the desire to maintain an equal playing field and have all teams remain competitive for the duration of the season. But a rule cannot be put in place dictating how GM’s construct their rosters and lineups on a daily or weekly basis. Based on the foregoing, we suggest implementing a general good faith requirement which allows the commissioner committee the right to investigate any alleged malfeasance. If indeed the committee believes an offending GM’s actions unreasonably violate the spirit of competition without at least furthering a personal goal in the process, then punitive measures such as suspension, expulsion or monetary fines can be enforced.


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