Out of Luck vs. Colt-45 – 6 F.J. 619 (November 14, 2014) – Fantasy Football Trade Rejected (P.Manning/L.McCoy/A.Peterson)


Out of Luck vs. Colt-45


Decided November 14, 2014
Cite as 6 F.J. 619 (November 2014)

Factual Background

A fantasy football league called the Armchair Quarterbacks League (hereinafter referred to as “the AQL”) is a 10-team PPR redraft league hosted on Yahoo.   Trades are approved automatically upon acceptance without any commissioner approval or league vote initiated.  GM’s who dispute a trade for violating the league’s integrity through collusion or roster dumping are responsible for purchasing the Court’s services.

Out of Luck, currently 6-4 in 4th place and in playoff contention traded Phillip Rivers (QB-SD) and Adrian Peterson (RB-MIN) to Colt-45 (3-7 and in last place) in exchange for Peyton Manning (QB-DEN) and LeSean McCoy (RB-PHI).

Procedural History

Numerous managers in the league disputed the trade believing that Colt-45 is making a dump trade, or even worse colluding with Out of Luck.  Currently Out of Luck is 108.92 points behind the team with the most points for the season.  The team that ends the year with the most points wins $600.00.

Issues Presented

(1) Should the trade between Out of Luck and Colt-45 be approved?


When presented with allegations or suspicions of collusion, the Court will look at the evidence in the light most favorable to the accused.  This is because acts of collusion within a fantasy league are one of the most serious fantasy sports crimes that can be committed and can undermine the integrity of a league more so than almost anything else.  See Team Zero vs. Samcro Reaper Crew, 3 F.J. 177, 179 (October 2011).

Before we delve into the analysis of collusion, we must address an inherent problem in the AQL which is a possible source of the dilemma in this case.  The fact that Colt-45 was able to still make trades with a 3-7 record in this redraft league is problematic.  Clearly he is not building for the future or selling off assets to stockpile draft picks because the AQL is not a keeper league.  At 3-7, he is mathematically eliminated from playoff contention and any money prizes.  This entire scenario could have been avoided if there were rules in place prohibiting teams out of playoff contention from making trades.  See The KO Show vs. #CommishJinx #GonnaBBBepic, 6 F.J. 605 (November 2014) (holding that the Court’s typical threshold for teams in redraft leagues to be eligible to make trades is that they should be mathematically alive for a playoff berth).  We recommend amending the rules for next year to apply such a restriction.

Collusion is defined as a secret agreement or conspiracy between at least two parties especially for fraudulent or treacherous purposes.  See Steel Curtain vs. Rusty Trombones, 3 F.J. 201, 203 (November 2011) (holding that a secret agreement between teams to use the first waiver position as a means to move a player to another team further down the list was collusive because its purpose was to circumvent the established rules).  Without a confession or some form of written proof, the Court will rely on circumstantial evidence and weight the totality of the circumstances surrounding the trade(s) being made.  See John Doe vs. Richard Roe, 3. F.J. 197, 200 (October 2011).

We must consider the facts and circumstances of the case to determine whether, more likely than not, there was malicious intent that rises to the level of collusion.  Outside of written proof or verbal confirmation, there is no way to definitely prove the existence of such conduct.  Regardless, the Court can draw inferences from the evidence presented and the circumstances surrounding the trade whether collusive conduct is present.  See Tiger’s Blood vs. Hulkamaniacs, 3 F.J. 58, 61 (July 2011).

The only evidence we have been presented with in support of an allegation of collusion is the potential $600.00 winnings that Out of Luck can achieve if he ends the season with the most total points.  While this is a financial incentive for Out of Luck, there would need to be some form of quid pro quo for Colt-45 in order to determine collusive behavior between these teams.  See League Commissioner vs. Judges, et al. 3 F.J. 223, 225 (December 2011) (holding that having a financial interest in more than one team is an indicator of collusion).  However, there is no tangible evidence submitted which would lead us to believe that there is a mutual agreement in place to either share these winnings or assist Out of Luck in his pursuit of that prize.  We would be merely speculating about any underhanded agreement in place between the two parties, and that is not sufficient enough to determine a finding of collusion.

Just because we do not believe these two teams are colluding does not mean we find this trade fair and equitable.  In fact, our conclusion is just the opposite.  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).  We believe scenarios 3 and 4 apply here.

When analyzing the fairness and equity of a trade, the Court will consider each team’s individual needs to assess whether the trade subjectively made sense from each team’s perspective.  See Cajun Crawdads vs. Carson City Cocks, 1 F.J. 41, 42 (June 2010) (upholding a trade for Jason Bay because of the Carson City Cocks’ desperate need for a starting outfielder due to the demotion of Cameron Maybin).  It does not appear this trade improves Colt-45’s team in any capacity.  The AQL is a redraft league so we are not even considering any potential long-term benefits afforded.  Willie McGee’s Beauty Parlor vs. Sizemore Matters, 4 F.J. 29, 30 (April 2012).

The approval or rejection of a trade is based purely on its fairness, free from collusion, and in the best interests of the league.  Whether a trade is intelligent or popular will not be part of the analysis.  See 4 Ponies vs. Beaver Hunters, 3 F.J. 26, 27 (June 2011).  The virtue of a trade is measured in both quantifiable criteria and subjective needs of the teams involved.  See Carson City Cocks vs. Stud Muffins, 3 F.J. 23, 24 (May 2011).

This trade of Peyton Manning and LeSean McCoy in exchange for Philip Rivers and Adrian Peterson does not pass the initial “sniff test” where an objective analysis could be provided to equate the value and performance of the players involved in this deal.  This deal is so grossly lopsided that doing any type of statistical comparison would be a waste of judicial economy.  See Tiger’s Blood vs. Hulkamaniacs, 3 F.J. 58, 60 (July 2011).

Lopsided trades throw off the competitive balance of the league and create a slippery slope for future trades.  The Court has no issues with the idea of trading superstar players so long as the package in return is equitable and makes sense given the needs of both teams.  See 4 Ponies vs. Beaver Hunters, 3 F.J. 26, 29 (June 2011).  However, there is no rational basis for Colt-45 to make this trade.  As good as Philip Rivers has been this year, Peyton Manning is infinitely better and more valuable for the rest of the season.  In addition, Adrian Peterson has missed all but one game and his status for the remainder of the season is in serious doubt.  While LeSean McCoy has had a disappointing season thus far, he is still an elite running back and far more valuable than a player who isn’t even active right now.

A trade will be rejected when the Court cannot objectively ascertain any benefit to one of the teams and the net result in no way makes a team better now or in the future.  See Los Pollos Hermanos vs. Little Stumps, 3 F.J. 192, 195 (October 2011); see also Speedboys vs. Kramerdogs, 5 F.J. 109 (July 2013) (rejecting a trade of Paul Goldschmidt, Adam Wainwright and Rafael Soriano in exchange for Bryce Harper, A.J. Burnett Trevor Rosenthal, and Archie Bradley).  We cannot comprehend any justifiable argument as to a potential benefit towards Colt-45 in making this trade.  Allowing this trade to go through would have a detrimental effect on the league and it undermines the AQL’s integrity.  Based on the foregoing, the Court rejects the trade between Out of Luck and Colt-45.


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