New Fantasy Judgment decision – Jersey Shore GTL v. Professional Amateurs (fantasy baseball issue)

THE SUPREME COURT OF FANTASY JUDGMENT 

Jersey Shore GTL v. Professional Amateurs

 ON PETITION FOR WRIT OF CERTIORARI FROM

THE CALIFORNIA PENAL FANTASY BASEBALL LEAGUE

 Decided March 17, 2011

Cite as 3 F.J. 1 (March 2011)

Factual Background

A rotisserie fantasy baseball league named the California Penal Fantasy Baseball League (hereinafter referred to as “CPFBL”) utilized an auction-style draft hosted on Yahoo’s fantasy baseball commissioner platform.  The CPFBL is a 12-team rotisserie league using both AL and NL players with each team allowed to keep up to five players for a maximum of three seasons.  Like many rotisserie leagues, the CPFBL is a 5×5 league using the standard hitting and pitching categories (AVG, HR, RBI, Runs, SB, W, ERA, K’s, SV, WHIP).  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 25 players and then $100 to purchase free agents after the draft has concluded.

The CPFBL draft is scheduled to take place on Sunday, March 27, 2011 at 12:00 PM CST.  The rules and guidelines of the league are delineated in a written document called the “CPFBL Constitution.”  Contained within the CPFBL Constitution is a section entitled “Trading and Transactions” which is marked as Article III.  Under Article III is a provision III.A entitled “Trades Between Teams” which includes the following pertinent sub-provisions:

1.   Teams shall be permitted to trade players during the off-season, which is defined as the time period starting the day after the conclusion of the World Series through the day before the next season’s draft.

4.   Teams shall not be permitted to trade draft picks or any other intangible asset.

5.   Trades made between teams must be of fair value and free from collusion.

8.   The CPFBL Commissioner shall have sole authority to approve or reject all trades proposed and entered into.

Procedural History

Two teams in the CPFBL – the Professional Amateurs and Jersey Shore GTL – attempted to make a trade prior to the league’s draft that has been rejected by the league’s Commissioner.  The Professional Amateurs offered Tim Lincecum-SP-SF, in the final year of his contract, to Jersey Shore GTL in exchange for Brett Anderson-SP-OAK plus $30 in salary cap flexibility. 

The Commissioner rejected this trade on the basis that the league’s Constitution prohibiting trades involving intangible assets.  The Commissioner reasoned that the $30 in salary cap money is intangible and cannot be traded according to the league’s rules.

The Professional Amateurs and Jersey Shore GTL have challenged the Commissioner’s ruling by arguing that the $30 is tangible since it will be used to draft players at the auction, and that it represents fair monetary value for Lincecum.

Issue Presented

(1)   Should the trade between the Professional Amateurs and Jersey Shore GTL be upheld and approved?

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.  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.

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 not been presented with any evidence of such malfeasance, so assumptions will be made that this is not an issue. 

Normally the Court will look at the players involved in the trade and arbitrarily render an opinion on the fairness and equitability of the subject players’ talents, abilities and statistics.  However, this is an issue of first impression as the Court has never been faced with an attempted trade of players in exchange primarily for salary cap money.  Without question, the trade of Tim Lincecum for Brett Anderson straight up is not an even trade, despite Lincecum being in the final year of his fantasy contract.  Anderson is a highly touted young pitcher with great potential, but he is far from the level of the two-time Cy Young award winner. 

Before analyzing the legality of the trade, the Court will take this opportunity to state that Brett Anderson plus $30 in salary cap money does represent fair value for Lincecum.  In many auction drafts researched by the Court, Lincecum’s value has ranged on average between $25 – $38.  On its face, the trade as proposed is fair.

However, the Commissioner properly rejected this trade based on his interpretation of the CPFBL’s Constitution.  The Supreme Court of Fantasy Judgment is a strong advocate for having written Constitutions that govern fantasy sports leagues because “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, there was clear language in the Constitution that prohibits trading intangible assets.  While the rules do not specifically list salary cap money under the definition of “intangible asset,” the Court can clearly interpret that salary cap money is inclusive in this provision.  The rules also state that the Commissioner has sole authority to approve or reject trades.  Here, the Commissioner was well within his authority to make this decision, which happens to be the correct one pursuant to the rules that govern the league.  Despite arguments made by the teams involved, the Commissioner rejected the notion that salary cap money was not considered an intangible asset.  The Court bolsters this position by holding that the league does not permit trading draft picks, which is arguably the same thing as salary cap money.  They both are intangible assets that can be used to acquire players.  Because there is no distinction between the two, the Court agrees with the Commissioner’s decision.

Further, this trade should not be permitted because it would violate the salary cap limitations set by the Commissioner and Yahoo.  If the trade was allowed, then the Professional Amateurs would have $290 in salary cap money to bid on players.  This directly contradicts the settings of the league where each team is permitted $260. 

Based on the aforementioned reasons, the Commissioner properly rejected this trade between the Professional Amateurs and Jersey Shore GTL.  The Court hereby upholds the Commissioner’s decision and rules that the subject trade should be rejected as it is in direct violation and contradiction of the league’s explicit rules.

IT IS SO ORDERED.

Fantasy Judgment Decision – All in the Family

THE SUPREME COURT OF FANTASY JUDGMENT

Iceman v. George and Joker’s Wild

 

 

  

ON PETITION FOR WRIT OF CERTIORARI FROM

THE LEAGUE OF EXTRAORDINARY GENTLEMEN

Decided October 10, 2010

Cite as 2 F.J. 18 (October 2010)

 

Factual Background

 

A fantasy football league called the League of Extraordinary Gentlemen (hereinafter referred to as “LOEG”) is comprisedof 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 trading prohibit any act of collusion and also prevent teams eliminated from playoff contention from entering into deals. The trade process must be administered through CBSSports league website or via email from both parties. After a trade is submitted through CBSSports, the approval process is delineated in the LOEG’s Constitution with the following language:

5.2 Trades should always be allowed unless collusion is suspected. Collusion is defined as “a trade in which one of the owners knowingly and purposefully aids another owner without benefit to his own team.” The commissioner has authority to reverse trades where collusion has occurred. The deputy commissioner has authority to reverse trades involving the commissioner where collusion has occurred. If a member of the league feels that collusion has occurred between the commissioner and deputy commissioner, the trade will be put to a majority vote (owners may abstain from voting). A tie vote approves the trade.

On Tuesday, September 21, 2010, George and Joker’s Wild made a trade which was the subject of Jetnuts v. George, et al., 2 F.J. 15 (2010). In that trade, George traded Michael Vick to Joker’s Wild for Percy Harvin. The Court ruled that this trade was fair and the process in which it was made between father and son was also fair (discussing trades before they are officially entered into is not indicative of collusion).

During the week of October 5-10, 2010, George and Joker’s Wild have made another trade. George has agreed to trade Knowshon Moreno (RB-DEN) to Joker’s Wild in exchange for Ben Roethlisberger (QB-PIT).

Procedural History

 

As per the rules of the LOEG, trades and trade offers must be made through the league’s website on CBSSports.com or when both teams involved in the trade independently inform the LOEG Commissioner. Under CBSSports’ settings, trades entered on Tuesday will go into effect for the upcoming week’s games. Trades are permitted between any team so long as that team is still mathematically eligible to reach the LOEG playoffs. Additionally, trades must not be made under the auspices of collusion or “under the table” agreements between teams.

Iceman has appealed this trade between George and Joker’s Wild arguing that the trade’s nexus stems back to the September 21, 2010 trade between these same teams. Iceman argues that the first trade was made with the intent to make the subject trade when Ben Roethlisberger was activated by the Pittsburgh Steelers. Iceman relies on the fact that in between the trades, George released Carson Palmer (QB-CIN) because he knew he was going to acquire Roethlisberger. Iceman is essentially claiming that there is collusion between George and Joker’s Wild based on these two trades they have made with each other.

Joker’s Wild justified the trade by the fact he already possessed Michael Vick and Philip Rivers on his roster and had no need for a 3rd

quarterback, especially one of Roethlisberger’s caliber who also had significant trade value. George also denied any premeditated action regarding the second trade as he claims he had no knowledge of his acquisition of Roethlisberger when he dropped Carson Palmer.

  

Issue Presented

(1) Should the trade between George and Joker’s Wild be approved?

(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.

As with the previous case involving a trade between George and Joker’s Wild, the LOEG’s Constitution clearly delineates the rules and guidelines for making trades between teams. While CBSSports.com dictates when trades can be input in order to become effective for the upcoming week’s teams, there are no known restrictions on when teams can begin negotiating trades. This includes possibly discussing trades that may not go into effect for several weeks. In any type of fantasy sports negotiation, the groundwork for making a deal is usually laid ahead of time. Even assuming that George and Joker’s Wild discussed this second trade several weeks ago, there is nothing inherently wrong, illegal, or unethical about doing such a thing. Additionally, the trade of Knowshon Moreno for Ben Roethlisberger is fair and even. Moreno has been inactive for the last several weeks with a hamstring injury, and Roethlisberger has been serving a suspension and hasn’t even played a down yet in 2010. If the actual trade being challenged was lopsided or uneven, then the argument of collusion would have more clout. Here, both teams are receiving a benefit and both players involved have enough talent and star power at premium positions to justify a trade for each other.

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. There is no reason to hold family members under any additional scrutiny when making trades outside of evidence supporting a collusive effort. Here, no evidence of collusion has been presented to warrant such an investigation or analysis. While family members may have more direct contact and communication than other members of the league, that does not inhibit or prevent teams from making deals with those family members. It is apparent that other teams in the LOEG are suspicious of the dealings between George and Joker’s Wild because they are father-son. This is unfortunate because the Supreme Court of Fantasy Judgment, who is an advocate for all things that are fantasy sports, especially encourages 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. From the evidence presented to the Court regarding the trades made between George and Joker’s Wild, there does not appear to be any sort of collusion or under the table agreements in place. The Court is most concerned about maintaining the integrity of the LOEG, and there does not appear to be any reason to think the league’s integrity is in jeopardy based on the dealings between George and Joker’s Wild. However, the Court is growing concerned about the repeated public skepticism of George and Joker’s Wild’s relationship and dealings. This issue must be dealt with between the Commissioner and the rest of the league before things unravel.

The plaintiff’s arguments about what was intended weeks ahead of time are speculative and not demonstrated by the evidence submitted. The Court hereby decides that the trade between George and Joker’s Wild should be upheld as it is both fair in value and made without any evidence of collusion.

IT IS SO ORDERED.