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.