Charleston Carlsons vs. League Commissioner – 6 F.J. 602 (November 9, 2014) – Fantasy Football Dispute (Commissioner’s Discretion)


Charleston Carlsons vs. League Commissioner


Decided November 9, 2014
Cite as 6 F.J. 602 (November 2014)

Factual Background

A fantasy football league called the Chi-Town Keeper Fantasy Football League (hereinafter referred to as “CTKFFL”) is a keeper league where teams compete against each other on a weekly basis during the National Football League (“NFL”) season using the statistics of professional players as a basis for accumulating points in head-to-head competition with opponents to determine which fantasy team won or lost.  Players can only be added through the waiver wire process which only runs on Thursday and Saturday.  The CTKFFL is hosted on the ESPN fantasy football platform and is not governed by a league constitution.

The Charleston Carlsons were traveling out of the country during the week and returned on Saturday night, November 8, 2014.  On the morning of Sunday, November 9, 2014; the Charleston Carlsons traded Odell Beckham, Jr. (WR-NYG) and Joe Flacco (QB-BAL) to the Black Bears on Twinks in exchange for Philip Rivers (QB-SD).  Upon realizing Rivers was on a bye week, the Charleston Carlsons realized that they needed did not have a starting quarterback for the week.

Since waiver wire transactions were already closed, the Charleston Carlsons contacted the CTKFFL commissioner at 12:30 PM EST to see if a waiver wire claim could immediately be made for Kyle Orton (QB-BUF).

The commissioner confirmed via phone call that the Charleston Carlsons could pick up Kyle Orton for $5.00 off waiver claims prior to the 1:00 games beginning if approval was received from his opponent, the Delaware Donkey Dicks.  The commissioner, Charleston Carlsons and Delaware Donkey Dicks participated on a three-way phone call where approval was given by the Delaware Donkey Dicks.  As such, the transaction was processed adding Orton into the Charleston Carlsons starting lineup.

Procedural History

Upon announcement to the league, three other GM’s expressed their concerns saying this was cheating and calling for a league vote.  Without hesitation or implementing a league vote, the commissioner negated the transaction after games started for the week.  This left the Charleston Carlsons without a starting quarterback for the week.

It has been disclosed that a similar scenario arose earlier in the season where the commissioner offered the same recourse to another GM who chose not to act upon it.

Issue Presented

(1) Should the commissioner have negated the waiver wire transaction after previously approving it?


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).

The CTKFFL is not governed by any set of written rules or a constitution which could provide guidance on how to adjudicate a scenario such as this.  Without a constitution, the league commissioner must rely on precedent, common sense, and the best interests of the league when making critical decisions such as this.  See Didn’t Hit Submit vs. Commissioner, 1 F.J. 23, 26 (January 2010).  The commissioner will typically have the final say on issues that fall outside the scope of the league’s host site’s parameters.  See Dwayne Bowe Peep vs. The Boston Tea Party, 3 F.J. 188, 190 (October 2011).

Since there is no constitution or separate written set of rules with respect to transactions, the league’s settings on ESPN are the default standard by which to adhere.  However, without a constitution, the commissioner retains the discretion on whether to afford any type of leniency when there are extenuating circumstances present.  See Winners vs. Seven Shades of Shite, 3 F.J. 97, 104 (July 2011).  In this instance, the Charleston Carlsons were out of the country until Saturday night.  The record is devoid of any details regarding whether they had internet access or technological capabilities to access their roster.  But we can presume that the commissioner was aware of this dilemma since he afforded the Charleston Carlsons the opportunity to acquire a quarterback after the waiver process had concluded.

It has also been submitted that the commissioner previously granted similar recourse to another team earlier in the season.  In that case, the GM chose not to accept the leniency for reasons not known to the Court.  This prior incident established a precedent by which the commissioner relied upon to offer similar recourse to the Charleston Carlsons.  We cannot speculate as to how the other teams in the league would have reacted to the initial instance, but the commissioner was well within his discretion and authority to offer such relief.

The issue here is that the commissioner premised his decision for the Charleston Carlsons on that precedent but then reversed course after games had already begun.  It is imperative that a league commissioner make critical decisions like this timely and decisively to help maintain the overall integrity of the league.  Fair and Balanced vs. League Commissioner, 5 F.J. 1, 3 (January 2013).

If he so chose, he could have denied this remedy in the first place upon the Charleston Carlsons’ initial request even though it was previously offered earlier in the season.  But the fact remains he set conditions for the late waiver wire transaction which were met by the opponent’s approval.

It is understandable why other teams might oppose such leniency.  Technically the Charleston Carlsons did not submit waiver wire bids in a timely manner.  However, there were extenuating circumstances which arose to permit the commissioner to grant an exception.  In addition, the commissioner properly required the opponent’s approval since he was the one who would be directly affected by such a decision.

One positive aspect of how the situation was handled was not calling for a league vote.  There are no rules in place which permit a league vote to decide issues such as this when they arise during the course of the season.  Had a league vote taken place, we would ignore the results because there was no provision delineated in the league rules or precedent established internally for resolving an issue in this manner.  See Ryan Braun’s Kosher Urine vs. League Commissioner, 4 F.J. 20, 22 (February 2012).

The commissioner had the authority to grant the relief requested.  He took the proactive steps of properly setting up conditions for the waiver wire transaction to be processed.  Once the conditions were met with approval by the Delaware Donkey Dicks, the transaction was processed before game time so no one was prejudiced.  It was improper for the commissioner to subsequently change his mind once games started and reverse course.  He had an opportunity to deny the relief requested initially, but chose not to.  This is not to say that all league members have carte blanche to seek last minute waiver wire transactions.  Each instance should be evaluated on a case-by-case basis, and it is the commissioner’s discretion to determine whether leniency should be granted if there are extenuating circumstances such as this.  It is crucial for the commissioner to maintain a consistent evaluation of each circumstance and provide a thorough justification why he reaches whatever decision is made.  See Machine vs. Fantasy Football League Commissioner, 2 F.J. 1, 3 (September 2010).  But reversing his own decision after games had begun was the wrong course of action to take and undermines his own decision-making authority.  The Court rules that Kyle Orton should be in the Charleston Carlsons’ lineup for Week 10 after being acquired for $5.00 pursuant to an exception made and approved by his opponent for the week.


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