New Fantasy Judgment decision – fantasy baseball issue (FAAB)

SUPREME COURT OF FANTASY JUDGMENT

A-Holes & Pujols v. Mad Cow Disease 

ON PETITION FOR WRIT OF CERTIORARI FROM THE SOUTHERN CALIFORNIA ALL-STAR FANTASY BASEBALL LEAGUE

Decided June 27, 2011

Cite as 3 F.J. 44 (June 2011)

Factual Background

A rotisserie fantasy baseball league called the Southern California All-Star Fantasy Baseball League (“SCAFBL”) is a mixed NL-AL non-keeper league comprised of 12 teams utilizing the standard 5×5 scoring categories to determine the standings and prize money.  For offensive players, the five categories are: (1) batting average; (2) homeruns; (3) runs batted in; (4) runs scored; and (5) stolen bases.  For pitchers, the five categories are: (1) wins; (2) earned run average; (3) WHIP (walks+hits/innings pitched); (4) strikeouts; and (5) saves.  Statistics are cumulative throughout the course of the season and there are no head to head games contained within the Roto league.

The SCAFBL operates under a written Constitution which outlines all of the league’s rules and guidelines.  Each league member was provided with a copy of the Constitution prior to the league’s draft which took place on March 27, 2011.  Included in the rules are provisions regarding the process and method of inputting transactions, including add/drops, placing players on the disabled list, and making trades with other teams.  The SCAFBL employs an auction bidding process for free agents where each league member was allotted $100 to use in bidding for available players throughout the season.  The following represents a condensed and concise summary of the pertinent Constitutional language that governs the transaction process:

• Each team is given a budget of $100 to use on players available on the waiver wire.
• Teams are restricted to a maximum of five transactions per week.
• All bids on free agents must be made before the conclusion of the final Sunday night game of the week.
• Teams must make their transactions in conformity with the league’s roster and lineup requirements.
• The bidding process will be managed, controlled and administered by the CBS Sports internal commissioner service.
• The bidding process is blind and no team shall have access or knowledge of other teams’ bids.
• The SCAFBL commissioner shall not have access to other teams’ bids.

On Saturday, June 25, 2011, A-Holes & Pujols placed a bid on free agent Dustin Ackley (2B-SEA) for $12 using the CBS Sports free agent auction bidding process.  As his corresponding move, A-Holes & Pujols sought to drop Ben Francisco (OF-PHI).  A-Holes & Pujols made no other free agent auction bids or any other transactions for the remainder of that week.

As usual, the free agent auction bidding process was run by CBS Sports on Sunday night, June 26, 2011.  Once the auction was complete, Mad Cow Disease (also the SCAFBL Commissioner) was awarded Dustin Ackley by winning the auction with a bid of $14.  As a result, A-Holes & Pujols’ bid for Ackley was denied and Francisco remained on their roster.

Procedural History

On Monday, June 27, 2011, A-Holes & Pujols sent out an email to the entire league accusing the Commissioner of abusing his power and outbidding him for Ackley.  The basis for A-Holes & Pujols’ contention is the allegation that the Commissioner has access to everyone’s bids and can manipulate the system where he can outbid any team for a free agent he so desires.

In response to this email, the Commissioner emphatically denied such accusations and reminded the league of the provisions laid out in the league’s constitution (which are also delineated above in the Factual Background).  A majority of league owners responded to the emails as well affirming the Commissioner’s decree and lashing out at A-Holes & Pujols for the undeserved accusations. 

A-Holes & Pujols still refused to accept this explanation and requested a league vote to resolve the issue.  The Commissioner rejected this request, so A-Holes & Pujols have contacted the Court to rule whether the Commissioner’s acquisition of Dustin Ackley should be upheld due to his alleged capability to see all competing bids.

Issue Presented

(1)   Should the Commissioner’s acquisition of Dustin Ackley be upheld?

Decision

The Supreme Court of Fantasy Judgment is a strong advocate for having written Constitutions that govern fantasy sports leagues.  See John Doe v. Fantasy Football League Commissioner, 2 F.J. 21, 22 (October 2010).  Having a written league constitution or charter helps ensure that “all league members are aware of the rules and guidelines in place, and it shifts the burden onto the league members to read, understand, and adhere to the rules that are delineated.”  See Shawn Kemp is My Daddy v. Fantasy Basketball League Commissioner, 2 F.J. 24, 25 (October 2010).  Here, the rules explicitly stated what the procedures are for the FAAB process, including the fact that the bidding is blind and not even the Commissioner has access to other teams’ bids.  Not only were they delineated by the Commissioner in the league’s Constitution, but they are also the fixed settings set forth by CBS Sports in their League Commissioner package.  See Green Eggs & Hamels v. Megan Fox is Hot, 3 F.J. 4, 6 (April 2011). 

The Commissioner does subject himself to added scrutiny simply by having such inherent power as making the rules and having access to the league’s internal structure and settings.  However, those who choose to participate in a fantasy league run by a Commissioner should presumably have implicit trust and faith in that Commissioner – otherwise it would be foolish to entrust one’s money and time in a fantasy league run by someone that is not trustworthy. 

Here, the Commissioner is also a league member, which is often the case.  As Commissioner, he must make decisions that are in the best interests of the league.  However, he is also entitled to manage his team to the best of his ability and try to win.  The Commissioner is subjected to the same rules that apply to everyone else, including the provisions of the free agent auction bidding process.  The Commissioner is allotted the same budget as the rest of the league, and he must go through the same bidding process as everyone else.  Additionally, there is no way for the Commissioner, or anyone else in the league, to have access to other people’s bids pursuant to the settings that were input.  Any bid placed by the Commissioner is as blind as A-Holes & Pujols, and every other member of the SCAFBL.

Further, there is no way for a team to track when another team actually makes their bid.  A-Holes & Pujols stated that he placed his bid for Dustin Ackley on Saturday, June 25.  It is unknown when Mad Cow Disease placed his bid.  Irrespective of that, it simply does not matter when the bids are placed so long as they are placed prior to when the auction runs, which is typically just after 1:00 AM EST.  At that point, the only thing system cares about when running the auction is who bid more for a certain player.  Based on the blind bids placed on Dustin Ackley, Mad Cow Disease won the auction and successfully acquired the Mariners’ young second baseman.  

A-Holes & Pujols went to the rest of the league to appeal this.  The Commissioner, despite being involved in the situation, denied A-Holes & Pujols’ request for a league vote on the issue.  The Supreme Court of Fantasy Judgment advocates for league Commissioners to have a certain amount of authority and autonomy to run and administer fantasy sports leagues.  See FlemishUSA v. League Commissioner, 2 F.J. 35, 36 (October 2010).  In this case, the Commissioner appropriately ruled on the issue by denying the request for a league vote, and instead adhered to the clearly established rules and guidelines that govern the league and the FAAB process. 

The league’s FAAB rules clearly demonstrate that Mad Cow Disease (a.k.a. the league Commissioner) properly acquired Ackley.  The Court hereby upholds the Commissioner’s decision and rules that the subject transaction should be upheld. 

IT IS SO ORDERED.

New Fantasy Judgment Decision – Green Eggs & Hamels vs. Megan Fox is Hot (fantasy baseball issue)

THE SUPREME COURT OF FANTASY JUDGMENT

Green Eggs & Hamels v. Megan Fox is Hot

ON PETITION FOR WRIT OF CERTIORARI FROM

THE BRO’S BEFORE HO’S FANTASY BASEBALL LEAGUE

 Decided April 10, 2011

Cite as 3 F.J. 4 (April 2011)

Factual Background

A fantasy baseball league named the Bro’s Before Ho’s Fantasy Baseball League (hereinafter referred to as “BBHFBL”) is a 12-team rotisserie league using both AL and NL players with each team allowed to keep up to three players for a maximum of three seasons.  The BBHFBL is a 6×6 league using the following hitting categories – OBP, HR, RBI, Runs, SB, and Hits – and  the following pitching categories – W, ERA, K’s, SV, WHIP, and QS.  Statistics are cumulative throughout the season and each team will accrue points based on their standings for each individual scoring category.  Each team has a budget of $260 to draft 27 players and then $150 to purchase free agents after the draft has concluded.

The BBHFBL is governed by a Constitution that was authored by the league Commissioner and posted on the league’s CBSSports’ homepage.  All league members were notified via email and a message posted on the league’s message board that the Constitution was available for viewing on March 25, 2011. 

Contained within the BBHFBL Constitution is a section entitled “Transactions” which is denoted as Section 2.  Under Section 2, there are several provisions regarding the rules and guidelines for making add/drops utilizing a free agent auction bidding process (“FAAB”) including the following relevant language:

1.         Each team shall be given a budget of $150 to spend on free agents throughout the course of the season.

2.         In order to acquire a free agent, teams must bid at least $1 on a player and make a subsequent transaction by either dropping a player, moving a player to injured, or moving a player to the minors.

3.         The team that bids the most money for a free agent in a particular waiver period will be awarded that player. 

4.         Once a team has won an auction, that team will move to the bottom of the waiver priority order.

6.         If more than one team has bid the same amount of money on the same free agent, the team with the highest position on the waiver priority list shall be awarded that player.

9.         Waivers will run every day at 2:00 AM which means players can be added daily.

10.       Any disputes or challenges to the FAAB process shall be raised to the league Commissioner for inquiry to CBSSports.

Procedural History

Green Eggs & Hamels, a team in the BBHFBL, attempted to add Chris Capuano (SP-NYM) as a free agent on April 8, 2011.  He utilized the FAAB process on CBSSports and bid $1 on Capuano and dropped Bud Norris (SP-HOU).  This represented the second of Green Eggs & Hamels’ FAAB requests as he bid $14 to successfully obtain Brent Morel (3B-CHW) during the same April 8, 2011 waiver period.  Also on April 8, 2011, Megan Fox is Hot bid $1 on Chris Capuano and dropped Ross Ohlendorf (SP-PIT).

Because Green Eggs & Hamels successfully won the auction for Morel, he went to the bottom of the priority order for the next round of waivers during the period.  As a result, Megan Fox is Hot won the auction for Capuano despite bidding the same amount as Green Eggs & Hamels. 

Green Eggs & Hamels disputed this transaction to the league Commissioner arguing that he should have been awarded Capuano because placed the bid before Megan Fox is Hot.  The Commissioner rejected Green Eggs & Hamels’ arguments holding that the FAAB process explicitly states that teams will go to the bottom of the waiver order after winning a bid, and that the team that bids the most amount of money next down the waiver order will win that subsequent player.

Issue Presented

(1)   Should the Commissioner’s decision affirming Megan Fox is Hot’s acquisition of Chris Capuano be upheld?

Decision

The Supreme Court of Fantasy Judgment is a strong advocate for having written Constitutions that govern fantasy sports leagues.  See John Doe v. Fantasy Football League Commissioner, 2 F.J. 21, 22 (October 2010).  One of the primary reasons behind having a written Constitution is so that all league members are aware of the rules and guidelines in place that govern the administration and function of the fantasy league.  See Shawn Kemp is My Daddy v. Fantasy Basketball League Commissioner, 2 F.J. 24, 25 (October 2010).  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 rules explicitly stated what the procedures are for the FAAB process.  Not only were they delineated by the Commissioner in the league’s Constitution, but that is also the process as set forth by CBSSports as per the settings input by the Commissioner.  Green Eggs & Hamels was rightfully awarded Brent Morel with his first transaction because the $14 he bid on Morel represented the highest amount of money bid on an eligible free agent.  As a result, the auction for Morel went first and Hamels was awarded him.  Once Hamels won that auction, he automatically went to the bottom of the priority order for free agent pickups.  This meant that he essentially loses a tie-breaker in the event another team bids the same amount for a second free agent – which was the case here.  Because Megan Fox is Hot was higher on the priority order, he was correctly awarded Capuano.

Hamels appealed to the league’s Commissioner for review.  The Supreme Court of Fantasy Judgment advocates for league Commissioners to have a certain amount of authority and autonomy to run and administer fantasy sports leagues.  See FlemishUSA v. League Commissioner, 2 F.J. 35, 36 (October 2010).  In this case, the Commissioner appropriately ruled on the issue by adhering to the clearly established rules and guidelines that govern the league and the FAAB process. 

Based on the aforementioned reasons, the Commissioner properly rejected Hamels’ request for review as he was correctly denied obtaining Chris Capuano.  The league’s FAAB rules clearly demonstrate that Megan Fox is Hot properly acquired Capuano.  The Court hereby upholds the Commissioner’s decision and rules that the subject transactions should be upheld.

IT IS SO ORDERED.

Roto Fantasy Baseball League vs. Fantasy Baseball Rookie

Roto Fantasy Baseball League v. Fantasy Baseball Rookie

ON PETITION FOR WRIT OF CERTIORARI FROM

THE ROTO FANTASY BASEBALL LEAGUE

Decided April 29, 2010

Cite as 1 F.J. 25 (2010)

Factual Background

An anonymous fantasy baseball league (hereinafter referred to as “fantasy league”) is operated in a rotisserie style where certain batting and pitching categories count for accumulation of statistics performed by major league baseball players. In this fantasy league, batters can score points and assist in the overall league rankings in the following offensive categories: batting average, homeruns, runs batted in, runs scored, and stolen bases. Pitchers accumulate points and assistant in the overall league rankings in the following pitching categories: wins, earned run average, strikeouts, saves, and WHIP (walks+hits per innings pitched). Additionally, this fantasy league permits teams to trade players with each other.

According to the rules set up by the fantasy league commissioner using Yahoo’s fantasy commissioner services, the commissioner has the sole authority to approve or disapprove a trade between teams. There is no league constitution in place to govern the overall operation of the league. As it is set forth, the only advertised criteria for the commissioner to use in evaluating trades is his own subjective evaluation. There are no additional checks and balances in place, such as a league vote or self-imposed committee review.

This fantasy baseball league is comprised of twelve teams, each of which has a roster of twenty players. Each team must include nine offensive players and six pitchers in its starting lineups each week. The pitchers can be of any designation (i.e., they can all be starters, all be relievers, or be some combination of both as long as they total six). The offensive players must comprise of one catcher, one first baseman, one second baseman, one third baseman, one shortstop, three outfielders, and one utility player (he can be eligible at any offensive position, including designated hitter).

The commissioner began this fantasy league in 2005 and has run it ever since. Over the years, he has brought in new members to replace departing team owners. Most of the people he has brought into the league were personal friends with him, or at the very least, good acquaintances. Not all team owners know each other outside of the fantasy league. Besides interacting through email, chat rooms, message boards, or internal league instant messages, most team owners do not interact with each other outside of the fantasy baseball world.

One new league member that the commissioner brought into the league has no prior fantasy baseball experience (hereinafter referred to as “rookie”). Prior experience is not a prerequisite for fantasy baseball participation. However, all other league members in this fantasy league have some form of experience, whether it be in this league or another. The other league members have no say in the commissioner’s choice for entry into the league, nor do they know the background of these new league members. There are no provisions in the rules which permit league members to request this information from the commissioner.

The rookie has expressed interest in making trades with other teams in the league. However, he has only proven to be responsive to trade inquiries or negotiations with the fantasy league commissioner. As stated previously, the commissioner personally knew the rookie and brought him into the league. The rookie did not know any other league member prior to entering the league.

The rookie ended up trading Mark Teixeira, the first baseman on the New York Yankees, to the commissioner in exchange for John Lackey, starting pitcher on the Boston Red Sox, and Francisco Rodriguez, relief pitcher on the New York Mets.

Procedural History

This trade was put through and approved by the commissioner himself. The trade was permissible in that it was a two for one player trade and was made in a timely fashion during the middle of the week.

Given there is no league vote or opposition allowed to a trade, even one made by the commissioner himself, the other league members have no recourse prescribed within the confines of the league to challenge the validity of a trade.

An anonymous member of the fantasy league has contacted Fantasy Judgment to determine whether this trade made between the rookie and the commissioner is fair.

Issue Presented

(1) Is the trade of Mark Teixeira in exchange for John Lackey and Francisco Rodriguez fair?

Decision

When deciding whether this trade is fair, the Supreme Court of Fantasy Judgment will look at several factors to determine its validity. The first set of circumstances to establish are the structural parameters of this fantasy league. All that is known to the Fantasy Judgment universe is that it is a 12-team Rotisserie style league with typical 5×5 categories. It is not known whether it is a keeper or league or not. However, this does not matter as it will not figure into the analysis. Each team has a roster of twenty players, including nine batters, six pitchers, and five reserves. The Fantasy Judgment universe is also not aware of the involved teams’ rosters. There will be certain things assumed in regard to the rosters of the involved teams.

This fantasy league does not have a constitution that governs the overall league. The only rules that are in effect are the ones selected by the commissioner on Yahoo’s platform. Within these rules is the provision that the commissioner has sole authority to approve or disapprove of all trades, including trades that he is involved in. Teams must make trade proposals or inquiries within Yahoo’s platform, and once accepted, the trade goes to the commissioner for approval. There are no other rules or guidelines in place to handle challenges to the commissioner’s decisions.

When looking at the trade of Mark Teixeira for John Lackey and Francisco Rodriguez, the first thing this Court notices is that it is a first baseman in exchange for two pitchers. It is assumed that the rookie is in need of pitching while the commissioner may have a surplus in that category. Assuming this is true, the needs and motivations of the teams can be understood based purely on roster depth and strength.

Besides roster depth and strength, this Court looks at each player’s individual statistics as of the date of this decision. As of April 29, 2010, Mark Teixeira was batting .139 with two homeruns, nine runs batted in, ten runs scored, and no stolen bases. Clearly these are not impressive numbers for a player presumably drafted in the first or second round of any fantasy draft. However, it is directly consistent with Teixeira’s history. Ever since Teixeira reached the big leagues, he has always started the season extremely slowly leading fantasy baseball players to question their decisions to draft him. However, as has been the case every season, Teixeira begins heating up in May and ends each season with similar numbers, all averaging above thirty homeruns and over one hundred runs batted in.

As of April 29, 2010, John Lackey had two wins, no saves, eleven strikeouts, an earned run average of 5.08, and a WHIP of 1.65. These numbers are not spectacular either, especially for a top starting pitcher who just recently signed a lofty long-term contract with the Boston Red Sox and was projected to be the team’s number three starter. This would presume that Lackey would be facing other teams’ number three starters. The benefit of this is that Lackey, for all intents and purposes is a number one starter (as he had been for many years in Anaheim), and he would not have to go against other teams’ number one starters.

Finally, as of April 29, 2010, Francisco Rodriguez had one win, three saves, sixteen strikeouts, an earned run average of 0.84, and a WHIP of 1.21. Rodriguez, the closer on the mediocre New York Mets, has not had many save opportunities and does not figure to as the season goes on. Even when he has been in save situations, he is no sure thing.

It is fair to say that these three players all were playing below their respective expectations and did not have the statistics that fantasy baseball players are accustomed to seeing. However, Teixeira clearly has the biggest upside given his ability to help his fantasy team ascend several rotisserie categories, including homeruns, runs batted in, and runs scored. On the other hand, Lackey, who has a history of injuries as well, does not figure to make a significant impact on any category. He may end up winning 12-15 games with the Red Sox, but he will not be any great help with any of the other four pitching categories. At his age, he seems beyond the days of striking out 7-8 batters per game. Rodriguez’ primary upside in a rotisserie league is obviously the saves category. It was just two seasons ago that he saved an all-time record 62 games for the Angels. Expectations were high when he signed with the Mets, but not enough save opportunities have materialized for Rodriguez to even make a run at numbers like that. He is also no longer the once dominant flamethrower that he used to be, and at 28 years old, he is more hittable now than ever. This equates to more baserunners and a higher WHIP, so his value in the other pitching categories is not as prolific as it was a few years ago.

Based on all of the preceding arguments, this Court opines that the trade was not an intelligent one made by the rookie. However, that does not mean it was unfair. The rookie did acquire two pitchers with enough talent and statistical ability to justify the trade.

The more glaring issue that needs to be analyzed goes deeper than whether this particular trade is fair. The fact that the commissioner can approve his own trades is overtly questionable. On top of that, the fact he is trading with a league member he personally brought into the league who has no prior experience raises some serious concerns about the integrity of the commissioner. With good reason, the other league members are up in arms about this situation. Unfortunately, the trade made is not unfair. Additionally, there is nothing the other league members can do outside of either quitting the league or collectively requesting that the rules be changed going forward regarding the commissioner’s ability to approve trades. This Court, as it always does, recommends that the league draft a constitution to provide guidelines and rules that govern the league and any unforeseeable circumstance that may arise.

For the purposes of this case and in the best interest of the fantasy league, the Court concludes that the trade made between the commissioner and the rookie is fair and should be upheld.

IT IS SO ORDERED.