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Fantasy Judgment decision – October 26, 2010 (fantasy football trade dispute)
THE SUPREME COURT OF FANTASY JUDGMENT
Silveramo v. Nation
ON PETITION FOR WRIT OF CERTIORARI FROM
AN ANONYMOUS FANTASY FOOTBALL LEAGUE
Decided October 26, 2010
Cite as 2 F.J. 38 (October 2010)
Factual Background
A complaint has been filed by a member of an anonymous fantasy football league (hereinafter referred to as “FFL”) challenging a trade made between two other teams. It is unknown what website the FFL is hosted on. The complaint is also devoid of additional information regarding the structure of the league, including whether it is a keeper league or how many teams there are. It is also unknown what the FFL’s rules are regarding trades and the approval process. There is no reference to a league Constitution and no rules or guidelines were provided in the complaint.
Starting lineups in the FFL consist of the following: QB (1), RB (2), WR (2), TE (1), FLEX (1 – RB/WR/TE), K (1), and DEF/ST (1). The scoring system for the FFL is as follows:
Passing
Touchdown = 4 points
Every 40 Yards = 1 point
Bonus at 300 Yards = 3 points
Rushing/Receiving
Touchdown = 6 points
Every 20 Yards = 1 point
Bonus at 100 Yards = 3 points
Touchdown Bonuses
Passing, Rushing, Receiving TD of 40-59 Yards = 2 points
Passing, Rushing, Receiving TD of 60-79 Yards = 4 points
Passing, Rushing, Receiving TD of 80+ Yards = 6 points
Receptions
Each reception = .5 points beginning with the 4th reception.
0-3 catches = 0 points
4 catches = 2 points
5 catches = 2.5 points
The plaintiff has challenged a trade made between Silveramo, the 1st place team in his division (5-2), and Nation, the 3rd place team in his respective division (4-3). Silveramo has offered to trade LeSean McCoy (RB-PHI), Ben Roethlisberger (QB-PIT), and Brandon Lloyd (WR-DEN) to Nation in exchange for Chris Johnson (RB-TEN), Kevin Kolb (QB-PHI), and Jeremy Maclin (WR-PHI).
Procedural History
The complaining party, on behalf of the rest of the FFL, is challenging the validity of this trade. Specifically, they question how this trades improves Nation who gave up Chris Johnson, arguably the best running back in the NFL (and the likely #1 draft pick in most fantasy football leagues this season), in exchange for LeSean McCoy who is on a bye this coming week (Week 8). Additionally, the complaining party argues that Nation does not need Brandon Lloyd because, according to the complaint, “he has great receivers.” The receivers on Nation’s roster at the time of this proposed trade include Anquan Boldin (WR-BAL), DeSean Jackson (WR-PHI), and Roy Williams (WR-DAL). Finally, the complaining party argues that Ben Roethlisberger constitutes an upgrade at quarterback over Donovan McNabb and Matt Ryan. However, he questions the significance of this upgrade when only one quarterback is in the starting lineup every week.
It was conceded in the complaint that there is no suspicion of collusion or cheating between Silveramo and Nation. The nature of the complaint is whether the trade was intelligently entered into.
Issue Presented
(1) Should the trade between Silveramo and Nation be approved?
Decision
The Supreme Court of Fantasy Judgment typically favors individual fantasy sports participants and teams’ ability to make moves, transactions, and trades. See Smittydogs v. Moneyball, 1 F.J. 32, 33 (June 2010). 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. The Court also acknowledges that the analysis for evaluating trades is much different in a keeper league than a non-keeper league. A trade that may look uneven or lopsided on its face may receive a different opinion when it is involved in a keeper league. The reasons for this are obvious, but must be restated. In a keeper league, teams that are having unsuccessful seasons are more likely to continue to pay attention and make moves that will set themselves up for better success in the following season. They can do this by acquiring young talent that is not under contract within the league, or by dumping salary (assuming it is an auction league) and allowing greater financial flexibility to sign key players in the next season’s draft. In non-keeper leagues, there is no rationale for thinking ahead, nor is there any need to stockpile young, inexpensive talent. However, it is not known whether the FFL is a keeper league or not. As a result, the standard of review will assume that it is not a keeper league and the Court will analyze the players involved in the trade based on their current and past statistics and performance as opposed to projections for future NFL seasons.
Another factor that the Court must always consider is whether there is any collusion or under-the-table dealings going on between teams. As stated above, the complaining party has admitted that there are no allegations of collusion or cheating. Therefore, the Court will forego an analysis into this scenario.
At first glance, the trade of LeSean McCoy, Ben Roethlisberger and Brandon Lloyd in exchange for Chris Johnson, Kevin Kolb and Jeremy Maclin looks fair and even. The eye-catcher in this deal is clearly Chris Johnson, arguably the best running back in the NFL in both reality and in fantasy. Any trade involving the #1 overall pick and most dominant fantasy player is going to create controversy and invite skepticism. However, when the numbers and statistics are broken down, Johnson and McCoy are practically even.
Rush Yds Receptions Rec. Yards Touchdowns
Chris Johnson 662 17 66 7
LeSean McCoy 477 38 293 5
Johnson’s success has made him a target for NFL defenses, and it is obvious that teams are focusing on shutting Johnson down to prevent his prototypical breakout run. This means that putting up similar statistics to what he did in 2009 will almost be impossible. On the other hand, LeSean McCoy has become the focus of the Philadelphia Eagles offense in both the passing and running games. Cumulatively, McCoy currently has more total yards (770) than Johnson (728), has double the number of receptions, and is almost identical in scoring touchdowns. Consequently, there is not much of a drop-off at all in trading Johnson for McCoy. The argument that this makes no sense because McCoy has a bye week this weekend is speculative. While it is true that the Eagles have their bye week, analyzing the rationale as to why this trade was made and when it was made is a process that the Court refuses to do.
To help make up the perceived difference in trading Johnson, Nation was able to acquire Ben Roethlisberger and Brandon Lloyd. Roethlisberger is certainly an upgrade over Kolb as Big Ben has almost eclipsed Kolb’s statistics despite playing in three less games. Big Ben is also an upgrade over the other two quarterbacks that he now shares a fantasy roster with – Donovan McNabb and Matt Ryan. The question over the sensibility of this trade because teams only start one quarterback per week is unfounded. Any fantasy football participant has the right (so long as the roster and rules allow it) to accumulate as many backups for position depth, injuries, and trade bait. Nation’s acquisition of Brandon Lloyd was also needed because DeSean Jackson is questionable for the near future due to the severe concussion he sustained during Week 6. Nation clearly needed a wide receiver, and since the Eagles are off this week, he included Jeremy Maclin in the deal for Lloyd, who will immediately become a starter. His needs were clearly served and he got fair market value for Chris Johnson.
The exchange of fair value is also demonstrated by Silveramo’s acquisitions from his perspective. He acquired Kolb when he already has Michael Vick. The Eagles have shown that they can score points no matter who is playing quarterback. Having both the starter and backup ensures that Silveramo will have an effective starting quarterback every week. Acquiring Jeremy Maclin gives Silveramo a good QB-WR combination, which is just as effective no matter who the quarterback is in Philadelphia.
More importantly, the complaining party has admitted that he is not challenging this trade based on collusion, cheating or any other reason besides it being dumb. The scope of the Court’s authority is to govern and advise when there is a dispute as to the validity of trades, rulings, decisions or other issues that arise within fantasy sports leagues. Making a judgment on whether an individual did something stupid is not what the Court does. As stated earlier, teams should be given the opportunity to make deals and try and improve their teams, even if that means they will make unintelligent decisions from time to time.
Based on the fact that the players involved in the trade are fair and equal coupled with the admission that the complaining party seeks Court intervention due to the trade allegedly being “stupid,” the Court hereby decides that the subject trade is fair and should be allowed. The subjective reasons why teams make trades should not be speculated about unless there is tangible evidence of collusion and the nature of the complaint provides sufficient information and background to corroborate such a story.
IT IS SO ORDERED.
Fantasy Judgment decision – October 17, 2010 (fantasy football issue)
THE SUPREME COURT OF FANTASY JUDGMENT
Get Shorty & Iceman v. Joker’s Wild
ON PETITION FOR WRIT OF CERTIORARI FROM
THE LEAGUE OF EXTRAORDINARY GENTLEMEN
Decided October 17, 2010
Cite as 2 F.J. 28 (October 2010)
Factual Background
A fantasy football league called the League of Extraordinary Gentlemen (hereinafter referred to as “LOEG”) is comprised of ten (10) 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 LOEG is hosted on the CBSSports fantasy football platform. The league rules regarding setting a starting lineup are delineated in the LOEG Constitution under the Section 3 entitled “Regular Season.” The following is the language of the rule within the LOEG Constitution:
3.4 If an owner fails to set up a legal starting lineup, the CBS recommendations will be used to set it.
At 1:05 PM on October 17, 2010, Get Shorty visited the LOEG website on CBSSports and turned on the “Live Scoring” function to view his opponent’s lineup. He noticed that there was a note from the league stating that his opponent (Joker’s Wild) had an illegal lineup.
At 1:06 PM on October 17, 2010, Get Shorty sent a text message to the owner of team George, who happens to be the father of the team owner of Joker’s Wild. Get Shorty inquired with George as to what was going on since there was apparently an illegal lineup.
At 1:13 PM on October 17, 2010, Iceman visited the LOEG website on CBSSports and also noticed it said Joker’s Wild had 0 points due to an illegal lineup. Iceman noted that one of the bench players on Joker’s Wild’s roster was incorrectly listed as a Flex player instead of a WR (Brandon Lloyd-DEN).
By 1:30 PM, Joker’s Wild changed Brandon Lloyd’s position from Flex to WR, thus making his roster legal. CBSSports allowed Joker’s Wild to make this change without the need for Commissioner override. Iceman speculated that within minutes of George being made aware of his son’s illegal lineup, George called Joker’s Wild and notified him to correct it. Iceman insinuates that this is indicative of potentially ongoing collaboration between George and Joker’s Wild.
In the event Joker’s Wild had an illegal starting lineup, the rules state that the CBS recommendations would be used based on the projected number of points each player had. Coming into the week, Brandon Lloyd was projected to have 10.1 points for the week while DeSean Jackson was projected for 6.6 points. In the case of an illegal starting lineup, Lloyd would be the default option by CBSSports because he was projected to have more points than Jackson.
Under the rules of the LOEG and CBSSports, players can be moved in and out of starting lineups as long as those players’ NFL games have not begun for the week.
Procedural History
The plaintiffs, Iceman and Get Shorty, have filed this complaint arguing that Joker’s Wild had an illegal lineup from the start of the week and should not have been permitted to change his lineup after the 1:00 PM games began. Plaintiffs cited Section 3.4 of the LOEG Constitution as the basis for their complaint. In the complaint sent by the LOEG Commissioner to the Supreme Court of Fantasy Judgment on behalf of the plaintiffs, Get Shorty refers to Section 3.4 and recites the language as following:
3.4 If an owner fails to set up a legal starting lineup, the CBS recommendations will be used to set it.
The plaintiffs have conceded that Joker’s Wild, and any other team in the LOEG, can make changes to their respective lineups after the 1:00 PM games have started. The concession is with regard to players whose games have not started yet by the time lineups are amended. Plaintiffs contend that Joker’s Wild’s lineup was illegal from the start and the CBS recommendations should dictate who is in Joker’s Wild’s starting lineup.
The LOEG Commissioner’s official ruling was, in pertinent part:
“It was only a bench player listed as Flex instead of WR that made his lineup illegal. CBS allowed him to fix it on his own without Commissioner override. He had DeSean as the starter prior to gametime. If the move was illegal, CBS would not have permitted it. The official ruling is that Joker’s Wild can play DeSean Jackson today.”
Issue Presented
(1) Should the LOEG Commissioner’s decision to permit Joker’s Wild to correct his illegal lineup and keep DeSean Jackson as a starter be upheld?
(2) Is there collusion between George and Joker’s Wild?
Decision
The Supreme Court of Fantasy Judgment is a strong advocate for having written Constitutions that govern fantasy sports leagues. There are a myriad of reasons why the Court believes having a Constitution in place is the best way to run and maintain a fantasy league. One of the primary reasons behind this rationale is that all league members are aware of the rules and guidelines in place that govern the administration and function of the fantasy league. When a league Commissioner writes out the rules and distributes them to the league, it shifts the burden onto the league members to read, understand, and adhere to the rules that are delineated. If a league member has an issue, question or challenge to one of the rules in the Constitution, they are welcome to raise this with the Commissioner before signing it or agreeing to its codification.
Here, the LOEG Constitution clearly states the rule regarding the consequences of having an illegal starting lineup. As cited before, Section 3.4 of the LOEG Constitution states that “if an owner fails to set up a legal starting lineup, the CBS recommendations will be used to set it.” There is no ambiguity behind the meaning or interpretation of this rule.
In the complaint filed with this Court, plaintiff Get Shorty cited Section 3.4 but misquoted the exact language of the rule. Get Shorty omitted the word “starting” when referring to a legal lineup in his complaint. This omission is crucial in the Court’s decision. Because the language of the rule is clearly stated in the LOEG Constitution, the Court will accept that language of the rule as true and exact. As a result, Get Shorty’s misstatement of the rule will be deemed an error. The issue at hand has to do with a player on Joker’s Wild’s bench being categorized incorrectly as a Flex instead of a WR. There is no dispute that the starting lineup propounded by Joker’s Wild was accurate and proper.
When Joker’s Wild was made aware of this predicament, he went into CBSSports and was able to make the necessary changes to his roster without the need for assistance or approval from the LOEG Commissioner. This took place at some point between 1:15 – 1:30 PM on October 17, 2010 – either way, it was after that day’s games had already started. The fact that the players at issue who were either changed or modified were players whose games had not yet begun when Joker’s Wild made the changes.
The mere fact that the league rule explicitly refers to an illegal starting lineup and there is no dispute as to whether Joker’s Wild’s starters were correct and proper at the time, the Court will easily affirm the LOEG Commissioner’s overall decision. There was no harm or prejudice to either of the plaintiffs because Joker’s Wild’s intent was to start DeSean Jackson, and that is what he did. There was nothing remotely illegal about his starting lineup. If there was an issue with the positional denotation of his bench players, then that issue was resolved when Joker’s Wild went into his roster and made the changes that he was allowed and entitled to make.
A far more critical issue is one that this Court has previously addressed regarding the alleged collusion between George and Joker’s Wild. There have been two prior cases heard by this Court regarding challenges to trades made between George and Joker’s Wild. The nexus of these complaints has been the fact that George is the father of Joker’s Wild. As stated in Jetnuts v. George, et al., the fact that two team owners who are related made a trade is perfectly within the rules as well. That being said, George, as the LOEG Commissioner, must make decisions that are in the best interest of the league and not himself or his son. The fact that the subject issue involved his son and he made his decision which favored his son has led to continued and ongoing allegations of collusion.
As stated in prior litigation involving George and Joker’s Wild:
“the Supreme Court of Fantasy Judgment is an advocate for all things that are fantasy sports, and we especially encourage participation in fantasy sports amongst family members, including generational participation. The fact that a father and son are in a league together should not cause or create any additional skepticism unless such skepticism is truly warranted and deserved.”
There have been two prior trades between George and Joker’s Wild that the Court approved due to the fact that the trades were fair and there was no perception of collusion or any other under-the-table dealings between the teams. This complaint further alleges that George gave his son notice of the alleged illegal lineup which allowed him to make the necessary changes before the bench players could not be changed due to the 4:00 PM games starting. There is no concrete or definitive proof that George did in fact provide this notice with such intent. However, the inference can be made. The Court will not go so far as to conclude that there is some form of collusion between George and Joker’s Wild. However, the Court strongly reiterates its prior recommendation to the LOEG Commissioner to deal with this issue publicly so as to maintain the integrity of the league and avoid a complete loss of control.
The Commissioner’s decision to permit Joker’s Wild to keep DeSean Jackson in his starting lineup is affirmed because there was nothing illegal about his starting lineup. Based on the evidence presented, this decision was not made based on a collusive effort between the teams. However, the Court’s concerns and recommendations are noted above.
IT IS SO ORDERED.
