The Verdict: lineup lockout


Bro’s Before Ho’s vs. League Commissioner

Decided May 25, 2012
Cite as 4 F.J. 76 (May 2012)

Factual Background

A fantasy baseball league called the Alpha Male Fantasy Baseball League (hereinafter referred to as “AMFBL”) is comprised of 12 teams and has been in existence since 2007. The AMFBL, hosted on, utilized a snake format for its annual draft and auction bidding on free agents when making transactions. It is a mixed AL/NL non-keeper league where each team must maintain a roster comprised of 23 players including 15 starters and eight reserves.

The AMFBL is a head-to-head points league where each scoring period runs from Monday through Sunday. Teams face off against each other in head-to-head matchups each week and winners are determined by whichever team scores more points by the end of the scoring period.

As part and parcel of the league settings input by the AMFBL commissioner, each team is permitted to edit and enter their own lineups prior to the beginning of each week. Per the parameters established by CBS Sports, lineups and rosters freeze five minutes prior to the start of the first MLB game of the scoring period. At that time, league members are no longer able to make changes to their lineups. Only the league commissioner has access and authority to make changes to the rosters after they lock.

On Monday, May 21, 2012, the team owner of Bro’s Before Ho’s attempted to input his lineup on his team’s page on at 7:00 PM EST. However, when he was making his changes, it was for Week 9 which was the following week. Upon clicking on Week 8, it showed that his lineup was set to the previous week’s lineup which included two players on the disabled list. Because the lineups had locked, he was unable to make changes for Week 8.

Procedural History

At 10:45 PM on May 21, 2012, the team owner of Bro’s Before Ho’s emailed the AMFBL commissioner informing him that he was locked out of making changes to his lineup and requested the commissioner’s assistance in overriding the lockout. The commissioner rejected his request on the basis that the rules are clear about setting lineups and there were no extenuating circumstances to justify making the changes.

Bro’s Before Ho’s then took the issue to the entire league pleading his case and requesting permission from his opponent that week to allow the lineup changes. Several league members responded with some in favor of allowing the changes and others against it. His opponent, The Corleone Family, stated that he would go along with the decision if the commissioner chose to fix the errant lineup.

Despite all of the input, the commissioner maintained his position that Bro’s Before Ho’s lineup would not be changed. Bro’s Before Ho’s now brings this appeal to the Court seeking intervention and an overturning of the AMFBL commissioner’s decision.

Issue Presented

(1) Should the AMFBL commissioner’s decision to not retroactively correct Bro’s Before Ho’s lineup be upheld?


It is unknown whether the AMFBL is governed by a league constitution or other set of written rules. However, it is irrelevant to the issue at hand because it deals with settings established on the league’s host site, The league commissioner implicitly agrees to adhere to and administer the settings as provided by with respect to rosters and lineups locking prior to the start of the scoring period’s games. Even assuming there is no league constitution, the commissioner’s power and authority is only limited to issues that fall outside the purview of the league’s host site’s parameters. Dwayne Bowe Peep v. The Boston Tea Party, 3 F.J. 188, 190 (October 2011).

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The Court typically favors fantasy sports players’ ability to make moves, transactions, and trades. 4 Ponies v. Carson City Cocks, 3 F.J. 13 (May 2011). This includes the ability to make roster and lineup changes as a league members sees fit. But this autonomy is limited to the confines of the established rules and settings of the league.

Fantasy sports league commissioners are empowered with the tasks of creating the league’s rules, settings, and guidelines. Bryan LaHair Club For Men vs. League Commissioner, 4 F.J. 26, 28 (April 2012). Once the AMFBL commissioner entered the league’s settings, including the scoring periods (Monday through Sunday) and the allowance for each team to enter their own lineups, his involvement with the administration of roster and lineup submission (besides for his own team) essentially ended.

It is indisputable that every individual who participates in a fantasy sports league is solely responsible for entering and submitting their lineups correctly and timely, regardless of the circumstances. Didn’t Hit Submit v. Commissioner, 1 F.J. 23, 25 (January 2010). Of course there can be extenuating circumstances that would warrant an exception, such as a personal tragedy or providing advance notice of an anticipated issue. But the commissioner is not under any obligation to deviate from precedent if he has in fact handled similar situations consistently. See Dwayne Bowe Peep v. The Boston Tea Party, 3 F.J. at 190.

The AMFBL commissioner has provided testimony that under no circumstances has he ever corrected a league member’s lineup for failure to enter it on time. The Court supports the notion that commissioners should enforce all rules and guidelines consistently. Winners v. Seven Shades of Shite, 3 F.J. 97, 104 (July 2011). If an exception is made for someone, it should be explained thoroughly justifying why such an exception is necessary. Machine v. Fantasy Football League Commissioner, 2 F.J. 1, 3 (September 2010).

Here, there was no viable extenuating circumstance to justify deviating from the precedent established. Bro’s Before Ho’s clearly did not intend to have a lineup with players on the disabled list. But attempting to make changes at such a late hour, while being on notice of when lineups lock for the week, places accountability solely on him for the error.

Another reason the commissioner correctly denied Bro’s Before Ho’s request for intervention is to prevent an injustice to his opponent, the Corleone Family. While the Corleone Family did indicate it would support the commissioner if he decided to make the changes, he still would have been unduly prejudiced. Bro’s Before Ho’s didn’t contact the commissioner until over three hours after games had started that day. By then, he had the benefit of seeing whether any of his players had scored points already and could have chosen them to substitute into his lineup. Even though these moves may have been logical and were his intent from the beginning, it still gives an air of impropriety that should be avoided.

While this is a relatively innocent mistake, the fact remains that it falls entirely on the shoulders of the appellant. The commissioner must do what is in the best interest of the league. The integrity of the league is paramount to almost any situation that can possibly arise, and that serves as the basis for the Court’s decision-making. See Victoria’s Secret v. C-Train, 2 F.J. 32, 35 (October 2010). If the established precedent is that the commissioner does not intervene on behalf of a team that errantly submit an untimely lineup, then that is how this current situation should be handled as well.

Based on the foregoing, the Court upholds the AMFBL commissioner’s decision to not allow retroactive lineup changes.


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Had a similar issue in a weekly points league.  The league was also in agreeance of not changing the teams line up retroactively.  The premise of the decision for us was simple, user error.  Once you have been in a league for a few years let alone 5 you should understand policies and procedures.

Michael A. Stein
Michael A. Stein

The Court agrees.  People should be responsible for knowing the rules and inputting their lineups on time.


I agree, the rules are the rules.  Especially when there is money involved.