Fantasy Judgment decision – December 1, 2010 (Rules are Rules)

        THE SUPREME COURT OF FANTASY JUDGMENT   

The Landry’s, et al. v. George, et al.

ON PETITION FOR WRIT OF CERTIORARI FROM

THE LEAGUE OF EXTRAORDINARY GENTLEMEN

Decided December 1, 2010

Cite as 2 F.J. 51 (December 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 the process and eligibility of making add/drops are delineated in the LOEG Constitution under Section 4 entitled “ADD/DROPS.”   The following is the language of the pertinent rule within the LOEG Constitution:

4.1  Free agent pickups and add/drops are unlimited and first-come, first-served from the conclusion of the initial waiver process (immediately after the draft) until kickoff of the first game of the season. After kickoff of the first game, player adds and drops will be done through a waiver process. The initial waiver order will be the reverse of the initial draft order. Once an owner acquires a player from waivers, that owner goes to the bottom of the waiver order. Each week, the waivers process starts the day after the last game of the previous week (typically this is the Tuesday after Monday Night Football). All available players (including dropped players) remain on waivers for at least one day (typically this day is the Tuesday after MNF) to ensure everyone has an opportunity to see and claim a player they might have interest in acquiring. The waivers process then is executed after the one day review period (typically on Wednesday morning at about 2:00 AM). Players who have gone through the waivers process are considered Free Agents. Free Agent pickups are unlimited and first-come, first-served starting immediately after the waiver wire is processed. Claiming a Free Agent does not change the waiver wire order. Players who are dropped as part of the waiver process then go on waivers for one day, and so on. Adds/Drops will be allowed throughout the playoffs until the final playoff game is started.  Once a team is eliminated from the playoffs, that team may not add or drop any players for the remainder of the season. Any timed adds / drops that appear to be collusion between teams are subject to review and potential reversal by the commissioner.

Last week, The Landry’s, who were already mathematically eliminated from playoff contention, successfully added Brian Westbrook (RB-SF) onto his roster due to his favorable position on the waiver order.  Concurrently, both the Jetnuts and George put in claims for Westbrook and were notified that they were denied their request due to Westbrook being acquired by The Landry’s.

George challenged The Landry’s acquisition of Westbrook to the LOEG Commissioner.  The Commissioner subsequently ruled that Westbrook would be removed from The Landry’s roster and awarded to the Jetnuts who had a higher waiver position than George (and both teams were still mathematically alive for a playoff berth).

Two weeks ago, Evil Empire (the team for the owner who also happens to be the league Commissioner) acquired Shaun Hill (QB-DET) when he was already eliminated from playoff contention.  Hill was not used in Evil Empire’s starting lineup and had no bearing on the result of the game between Evil Empire and The Landry’s, which was ultimately won by Evil Empire.  Due to the Commissioner’s ruling on the Brian Westbrook issue, The Landry’s now protest their game against Evil Empire where they allege Evil Empire’s lineup was illegal due to his improper acquisition of Shaun Hill.  The rules for challenging or protesting the scoring and results of games within the league are delineated under Section 3 entitled “REGULAR SEASON.”  The following is the language of the pertinent rule in the LOEG Constitution:

3.7 Any scoring challenges may be made only until noon on the Wednesday following the game in question.

The Commissioner provided the following response to The Landry’s protest and request for reversal of their prior matchup:

“It’s true that there is a rule prohibiting teams out of playoff contention from performing add/drops. I picked up Shaun Hill as a bench player quarterback on Wednesday November 25th, not realizing that we had that rule in our bylaws.  If they want me to drop Shaun Hill, I can do that. Since the move did not affect the outcome of a game, nor was it protested prior to the weekend games, I see no reason to issue my team a loss for this infraction.”   

Both The Landry’s and Iceman have made arguments before the Court in opposition to Rule 4.1, specifically the provision that prohibits teams eliminated from playoff contention from making add/drops.  The Landry’s argue that teams should be able to still compete for individual records and milestones, including highest point totals and largest margins of victory in the season.  Iceman argues that the concept of playing spoiler applies in fantasy sports as well where a team eliminated from playoff contention can still “play its Super Bowl” against a team still competing for the playoffs and have an effect on their ultimate outcome.

Procedural History

There are multiple claims made involving several LOEG teams.  The following represents a breakdown of the existing claims in this complaint:

1. George challenges The Landry’s acquisition of Brian Westbrook due to the fact that The Landry’s have been eliminated from playoff contention.
2. The Landry’s challenge the application of Rule 4.1 where his acquisition of Brian Westbrook was revoked due to the fact he was eliminated from playoff contention.
3. George challenges the Commissioner’s decision to award Westbrook to the Jetnuts due to the Jetnuts having a more favorable position in the waiver order.
4. The Landry’s protest their previous game against Evil Empire because Empire had improperly added Shaun Hill to his roster when technically he should not have been able to do so because he was already eliminated from playoff contention.

The Commissioner agreed with George’s challenge that Westbrook should not have been acquired by the The Landry’s and ruled that he belonged on the Jetnuts due to their more favorable waiver wire position.  The Commissioner also rejected The Landry’s request for a reversal of their previous game due to Shaun Hill being illegally placed on Evil Empire’s lineup. 

Issues Presented

(1)   Was the LOEG Commissioner’s application of Rule 4.1 correct and appropriate?

(2)   Should there be any exceptions to Rule 4.1 which would allow teams eliminated from playoff contention to acquire players via add/drop?

(3)   Should The Landry’s request for reversal of the results of his game against Evil Empire be granted?

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 process and eligibility for acquiring players through the add/drop waiver wire.  Within the confines of Rule 4.1, teams that are eliminated from playoff contention are not allowed to acquire players through the add/drop process.  Not only does the Constitution explicitly state this, but the legislative intent and purpose behind the rule is logical, reasonable, and promotes the maintenance of the league’s integrity by preventing potential collusion.  It is conceivable for a team with no chance of securing a playoff berth to sell off or trade his best players to a contending team with which he tries to strike a deal for a sharing of the monetary prize.  This rule specifically prevents that from happening by not even letting the teams susceptible to such temptation make roster moves.

The Commissioner made the correct decision to remove Brian Westbrook from The Landry’s roster after he was notified about the transaction.  Once The Landry’s officially was eliminated from playoff contention, they were not permitted to make any more add/drops as per the language contained in Rule 4.1 of the LOEG Constitution.  The Court surmises that there is no such capability on CBSSports.com to include a setting or rule that would prevent eliminated teams from making transactions.  If there is such capability, the Commissioner should certainly utilize it.  If there is not, then it is up to the Commissioner and all other teams to be diligent and police such activity – as was done here.

Once the Commissioner realized that Westbrook needed to be removed from The Landry’s roster, he had to determine which eligible team had the rights to acquire him.  George notified the Commissioner that his waiver request was denied in favor of The Landry’s, but he was not the only one.  According to the testimony of the Commissioner, the Jetnuts had also made a claim for Westbrook and possessed a more favorable waiver wire position that George.  As a result, the Commissioner correctly awarded Westbrook to the Jetnuts based on their higher position in the waiver order.  Had Westbrook not been added by The Landry’s, he would have correctly gone to the Jetnuts anyway based on the waiver order.

The Court has received arguments and testimony from both The Landry’s and Iceman concerning the applicability of Rule 4.1.  The Landry’s argues that teams eliminated from playoff contention are still competing and have individual goals they are striving for – as a result, they should be allowed to add players and continue to try and better their team.  Iceman argues that teams eliminated from playoff contention will get a chance to play spoiler, which becomes the equivalent of their Super Bowl because it would mean something to them to have a tangible effect on the overall playoff picture.  These points are well-received and the Court appreciates their dedication and attitude.  However, Rule 4.1 clearly denies eliminated teams the ability to add players.  This rule and the entire LOEG Constitution have been in existence and made available to the entire league since before the season began.  This issue should have been addressed or raised at the time the rules and Constitution were first made available to the league.  While The Landry’s and Iceman make valid arguments, they should be made during the upcoming off-season when the rules can/should be changed.  There is no valid reason to change the rules during the middle of the season outside of extreme and unforeseeable consequences.  See John Doe v. Fantasy Football League Commissioner, 2 F.J. 21, 22 (October 2010).  The Court would only support changing or adding to the rules in mid-season if it is the only option to prevent a complete mutiny or meltdown of a fantasy league.  This does not appear to be the case.  Part of the Commissioner’s responsibilities include recognizing when the time is right for an intervention of his power and authority. See George v. LOEG Commissioner, 2 F.J. 42, 43 (October 2010). The Commissioner should consider changing or amending Rule 4.1 if there is enough support within the league for such a change, and if the Commissioner believes it will be in the best interest of the league.

The Landry’s protest of their game against Evil Empire due to Empire’s previous acquisition of Shaun Hill is not valid.  Rule 3.7 of the LOEG Constitution clearly states that challenges to the scoring of games must be made by the following Wednesday at noon after that game in question.  Here, The Landry’s is clearly late in their submission of a protest as it was well beyond the window of opportunity to raise such a challenge.  However, even if the challenge had been made timely, their protest would be denied because Empire’s technically deficient acquisition of Shaun Hill would not have had an effect on the outcome of their game because he was not in the starting lineup.  Proper recourse could have been taken to remove Hill from Empire’s roster, and this still would not have had an effect on the outcome of the game.   

The Commissioner’s decisions to remove Brian Westbrook from The Landry’s roster and award him to the Jetnuts are affirmed.  The requests made by The Landry’s and Iceman in opposition to Rule 4.1’s prohibition of teams eliminated from playoff contention making add/drops are denied.  The Landry’s protest and request for a reversal of the results of his game against Evil Empire is denied.  The Court has considered all the evidence presented, but the overall consensus of the entire bench is that there are rules and guidelines delineated in the LOEG Constitution which clearly govern this particular activity within the league.  The fact that the Commissioner acted within the confines of the Constitution and applied the rules as codified gives rise to the Court’s decisions, which are made in the best interests of the league.

IT IS SO ORDERED.