Team FA vs. League Commissioner – 6 F.J. 656 (December 16, 2014) – Fantasy Football Dispute (Lineup Error)


Team FA vs. League Commissioner


Decided December 16, 2014
Cite as 6 F.J. 656 (December 2014)

Factual Background

A fantasy football league called the Sunday Funday Fantasy Football League (hereinafter referred to as “the SFFFL”) is hosted on ESPN.  Team FA was the #1 seed and had a bye during the first round of the SFFFL playoffs which took place in Week 14 of the NFL season.  The SFFFL semi-finals took place during Week 15 of the NFL season where Team FA was scheduled to play against Team S.  It should also be noted that the parties are located in the Central Time Zone so all times and dates reflect that.

At 10:44 AM on Sunday, December 14, 2014, Team FA added Matt Ryan (QB-ATL) and dropped Ryan Tannehill (QB-MIA) using the ESPN fantasy football app.  After adding Ryan to his team, he claims that he put him in as his starting quarterback.

At 12:03 PM, Team FA checked his phone to see his team’s projections and noticed that Matt Ryan was on his bench leaving his quarterback position empty as Ryan/was the only quarterback on his roster.  By this point, rosters had locked.

At 12:04 PM, Team FA sent a text message to the league commissioner requesting that he place Matt Ryan into his starting lineup.  The commissioner denied the request based on the fact that games had started already.  Specifically, the Pittsburgh versus Atlanta game that Ryan was playing in had already started.

Procedural History

Team FA ended up losing to Team S by five points.  Had Matt Ryan been in his lineup, Team FA would have won.  There is no record of Team S being notified of the roster mistake or the request by Team FA to the commissioner to place Ryan in his lineup.  In addition, the SFFFL does not have any separate rules besides the league settings on ESPN which locks lineups upon the start of games.

It is also stated that the SFFFL commissioner has not granted any such similar requests in the past.  However, Team FA claims that had he contacted the commissioner earlier he would have made the roster change for him.

Issues Presented

(1) Should the commissioner have put Matt Ryan into Team FA’s lineup?


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 SFFFL 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, Team FA relied on the ESPN app on his phone to complete the transaction of adding Matt Ryan for Ryan Tannehill.  When a player is added on ESPN, that player automatically is placed on the GM’s bench as a reserve.  The GM must make the additional move of placing that new player in his starting lineup.  It seems that Team FA did not do that here.

It is every fantasy league owner’s personal responsibility to enter and submit their lineups correctly, regardless of the circumstances.  Didn’t Hit Submit vs. Commissioner, 1 F.J. 23, 25 (January 2010).  That is not to say there aren’t exceptions which could be granted.  When there is no league constitution, the commissioner has the discretion whether to grant such requests depending on the circumstances.  See Charleston Carlsons vs. League Commissioner, 6 F.J. 602 (November 2014) (upholding the commissioner’s decision to allow a GM to make a late transaction due to being out of the country past the waiver wire deadline and gaining approval from that GM’s adversary in the upcoming week).

The circumstances surrounding the subject issue do not appear to rise to the level of necessity for the commissioner to grant the relief sought.  Team FA made the transaction at 10:44 AM and apparently did not realize Matt Ryan was not in his lineup until 12:03 PM, an hour and 19 minutes later.  There is no indication that Team FA had any type of technological or personal issues which precluded him from confirming his lineup after the transaction and before kickoff of the early Sunday games.

The other problem with this is that the Falcons vs. Steelers game was scheduled for a 12:00 PM (central) kickoff.  The text message exchange between Team FA and the commissioner took place after 12:00.  Commissioners should have a reasonable expectation that their fellow league members will alert them of any possible issues in a timely manner.  Romophobia vs. The Waterboyz, 4 F.J. 216, 218 (August 2012).  The notice provided by Team FA was not timely.  As such, it would be inherently unfair to make retroactive lineup changes once the games have started.

We acknowledge that Team FA intended to start Matt Ryan.  That is not disputed at all.  However, Team FA did not fulfill his duties and responsibilities to ensure that his lineup was entered properly.  He had ample time to accomplish this.  The commissioner even indicated he would have made the change if it was requested earlier.  But since Team FA did not make the request until after the game had started, he was left with no choice but to deny the request.  Additionally, there is no indication Team FA’s opponent was even consulted about this request.

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).  Here, the commissioner did respond promptly to the request and was justified in his decision.  However, he did have the discretion to grant the relief if he so chose but that would have also likely created issues as well.

When a league is not governed by a written constitution, the commissioner has the ultimate say on issues that do not fall within the purview of the host site’s parameters.  There may be some extenuating circumstances where the commissioner is more inclined to be lenient, but he is under no obligation to do so.  See Dwayne Bowe Peep vs. The Boston Tea Party, 3 F.J. 188, 190 (October 2011).  There were no extenuating circumstances in this case that would justify the commissioner making a lineup change after a game started.  As such, the Court upholds the SFFFL commissioner’s denial of Team FA’s request to add Matt Ryan to his starting lineup after the game had started.


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