Fantasy Judgment decision – October 29, 2010 (fantasy football trade dispute)
THE SUPREME COURT OF FANTASY JUDGMENT
Juicy Clams v. Butcher
ON PETITION FOR WRIT OF CERTIORARI FROM “THE LEAGUE”
Decided October 29, 2010
Cite as 2 F.J. 46 (October 2010)
Factual Background
A fantasy football league called The League (hereinafter referred to as “The League” – not to be mistaken with the FX television show called The League) is comprised of twelve (12) teams who 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. The League is hosted on the Yahoo fantasy football platform. There is no league Constitution in place to delineate the specific rules and guidelines to govern The League. There is no formal approval process to either accept or reject trades made between teams. The League’s Commissioner has the sole authority to either approve or reject trades made. It is unknown whether a different individual or committee is in place to approve or reject trades made involving the Commissioner.
The League’s point scoring system includes standard points for yardage accumulated by passing, rushing and receiving, 10 points per touchdown for all players (including team defenses), -4 points for all turnovers, and 3 levels of bonus points for yardage milestones for quarterbacks, running backs, wide receivers and tight ends. Rosters are comprised of 13 players, including 4 reserves at any eligible position. Teams must start the following players: QB (1), RB (2), WR (3), TE (1), K (1), and DEF (1).
On October 27, 2010, a trade was made between two team owners in The League. Juicy Clams (3-4) traded Adrian Peterson (RB-MIN) to Butcher (5-2) in exchange for Rashard Mendenhall (RB-PIT), Santana Moss (WR-WAS), and Lee Evans (WR-BUF).
Butcher brought Juicy Clams into The League, and the two of them work with each other. Additionally, Butcher is the brother of The League’s Commissioner. The League’s Commissioner subsequently approved the trade.
Procedural History
The League’s Commissioner seeks Fantasy Judgment’s affirmation of his decision to approve this trade. Other members of The League have vocalized complaints about the trade arguing that the trade is not fair and that there may be some collusion between Juicy Clams and Butcher.
The Commissioner does not believe there is any collusion and also ruled that the trade was fair since Juicy Clams helped fill multiple positions on his roster with the trade of a superstar like Adrian Peterson.
Butcher has submitted a brief to the Supreme Court of Fantasy Judgment in support of his argument that the trade was fair and made without a scintilla of wrongdoing. Butcher argues that his aggressive style of fantasy football is indicative of this trade, as well as his draft day trades where he dealt 8 draft picks in order to acquire 3 first round picks. Butcher further argues that the seeds had been planted for the subject trade a week before it was completed. He initially only offered Mendenhall and Moss for Peterson, but Juicy Clams only accepted the deal once Lee Evans was included.
Butcher contends that he is being scrutinized and punished by The League’s Commissioner (his brother) because has improved his team and is now a threat to the top two teams in The League. Butcher has provided a written attestation (to be used in lieu of an affidavit) that he has not entered into any side deals to share monetary winnings with Juice Clams or any other team in The League.
Issue Presented
(1) Should the trade between Juice Clams and Butcher be upheld where Adrian Peterson was dealt for Rashard Mendenhall, Santana Moss and Lee Evans?
Decision
The Supreme Court of Fantasy Judgment typically favors individual fantasy sports participants and teams’ ability to make moves, transactions, and trades. The standard of review has been that people pay money to purchase a team in a league, draft their team, and manage it accordingly. Whether success is bred from that individual’s decision-making is purely left to some skill, luck, dedication, and savviness. See Smittydogs v. Moneyball, 1 F.J. 32, 33 (June 2010).
Another factor that the Court must always consider is whether there is any collusion or under-the-table dealings going on between teams. The Court has been presented with some speculative evidence of potential collusion. However, the fact that two league members work with each other and one of them brought the other into the league does not meet the standard of proof necessary to prove collusion. There is no indication that a deal has been entered into between the teams to share players or profit. Just because two league members have a special relationship, such as family members or colleagues, should not preclude them from enjoying a fantasy sports league any less than others who do not have any privities. The mere fact that two league members have access to speak with each other discuss trades is not in itself any evidence of collusive efforts. Additionally, one of the teams involved is the Commissioner’s brother, so any wrongdoing would be a reflection on the Commissioner and it is unlikely that the Commissioner would want to subject himself to such skepticism or scrutiny. Based on the foregoing, the Court concludes that there is no collusion between Juice Clams and Butcher.
At first glance, the trade of Adrian Peterson in exchange for Rashard Mendenhall, Santana Moss and Lee Evans looks questionable because Peterson is arguably the second most prolific fantasy football player in the league and the three players he was traded for are not considered marquee superstars with equivalent value. However, based on statistics accumulated thus far in the 2010 season, the trade is not so lopsided. Peterson has rushed for 684 yards and 5 touchdowns. Compared to Rashard Mendenhall’s 532 rushing yards and 5 touchdowns, there is not a huge drop-off between the two as they stand today. Obviously Peterson is a better player and likely will finish the season with better numbers than Mendenhall. But Mendenhall is an effective starting running back on a good team in Pittsburgh and is likely to get the lion’s share of carries in close games down the stretch. On top of Mendenhall, Juice Clams also acquired Santana Moss and Lee Evans. Moss is Donovan McNabb’s primary target in Washington, and he has accumulated 548 receiving yards and 2 touchdowns to date. Evans has come alive the last couple weeks after being dormant for a month, much like the rest of the Buffalo Bills offense. Since Ryan Fitzpatrick has taken over at quarterback, the Bills have been impressive on offense, including putting up 34 points against a solid Baltimore Ravens’ defense. Evans has been at the center of this resurgence and has 286 receiving yards and 4 touchdowns, most of which have come within the last couple weeks.
Another factor to consider is that Juicy Clams have a very weak receiving core outside of Hakeen Nicks. This trade enabled Juicy Clams to replace Peterson with another solid and effective running back, as well as acquire two decent receivers to plug in for an injured Austin Collie and an underachieving Johnny Knox. The impetus for making such a trade may have been Juicy Clams’ panic after losing Tony Romo for possibly the whole season. This may have been a kneejerk reaction to what is going on.
Based on the evidence presented and the facts of this case, the Court holds that the subject trade should be approved. There is no evidence of any sort of collusive effort between Juicy Clams and Butcher. Additionally, the trade is fair. Other league members may have selfish reasons for not wanting the trade to go through or that would argue the trade wasn’t an intelligent one to make. The Court’s role is to evaluate whether a trade is fair in terms of being in the best interest of the league. The Court will not speculate or analyze the intelligence of one team over another based on a trade mutually agreed to. The Court’s role is to measure fairness and not judge stupidity. This trade is fair and should be allowed. Without evidence of collusion, these teams should be permitted to exercise their right to better their respective teams.
IT IS SO ORDERED.
