The Verdict: the court finds no collusion between repeat trade partners

The issue of potential collusion in a fantasy baseball league has been covered previously in this column. It is one of the biggest potential issues that can arise within a league for a variety of reasons. It is also extremely difficult to prove outside of an admission or other form of proof. But collusion can exist in many forms. Below is a Fantasy Judgment case that was submitted which involved suspicions of collusion between two teams that have a long history of only making trades with each other.


Garbage Pail Kids vs. Alex P. Keaton & Co.


Decided June 8, 2012
Cite as 4 F.J. 84 (June 2012)

Factual Background

A rotisserie fantasy baseball league called the 1980’s Fantasy Baseball League (hereinafter referred to as “roto league” or “1980’s”) is a 14-team AL/NL mixed keeper league and has been in existence since 2004. The league utilizes an auction-style draft and transaction platform on

Teams are permitted to maintain up to five (5) players during each off-season with individual players allowed to be kept for a maximum of three (3) consecutive years under contract. Each team is also permitted to keep three minor league players which are in addition to the five players kept. This roto league also has a $260.00 draft salary cap.

As with many rotisserie leagues, the 1980’s uses the standard 5×5 scoring categories to determine the standings and prize money. For offensive players, the five categories are: (1) batting average; (2) home runs; (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 league is governed by a written constitution which includes rules and guidelines regarding the making of trades between teams. The following represents the provision with respect to trades, in pertinent part:

Section VI. Trades

A. Trades are permitted between any two teams and are subject to approval by the league commissioner.

B. There is no limit to the number of trades that can be made by each team.

C. Trades may only be made up until the deadline of August 31, 2012. Trades may not be made again until after the conclusion of the 2012 World Series.

D. Trades are permitted in the off-season and are subject to the same approval process as delineated above.

* * * * *

G. The commissioner shall have the authority to reject trades made through collusion or that are otherwise completely lopsided to the detriment of the league.

H. Any trade made by the league commissioner shall be subject to approval by the co-commissioner.

* * * * *

L. There is no recourse for appealing the commissioner or co-commissioner’s decision regarding the approval or rejection of a trade. The league members hereby consent to the commissioner and co-commissioner’s authority and discretion to make such final decisions.

On June 4, 2012, a trade was made between the teams of Alex P. Keaton & Co. (“APK”) and a Flock of Seagulls (“FOS”). APK traded Shaun Marcum (SP-MIL), Rafael Soriano (RP-NYY), and Sergio Romo (RP-SF) to FOS in exchange for Anthony Rizzo (1B-CHC), Zack Wheeler (SP-NYM), Salvador Perez (C-KC) and Carlos Quentin (OF-SD). The commissioner subsequently approved the trade and an automated email was generated from CBS announcing the trade to the rest of the league.

Procedural History

After the other league members learned of the trade, the Garbage Pail Kids raised an issue with the commissioner regarding the number of trades made between these two teams, as well as the fact that APK hadn’t made a trade with any other team than FOS in several years. The Garbage Pail Kids essentially raised allegations of potential collusion and requested that the commissioner intervene.

The commissioner replied that there was no basis for an investigation into potential collusive conduct. However, to appease his league owners, the commissioner has submitted this case to the Court for review.

There are no questions raised by the league members about the equitability of any of the trades made between APK and FOS. As a result, the Court will not conduct an analysis of any trades made.

Issue Presented

(1) Is there any collusion between APK and FOS based on their pattern and practice of making trades with each other?


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). The Court strongly advocates for commissioners to codify these rules in a written constitutions for a myriad of reasons. John Doe v. Fantasy Football League Commissioner, 2 F.J. 21, 22 (October 2010).

One of the primary reasons to have a 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. 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. Shawn Kemp is My Daddy v. Fantasy Basketball League Commissioner, 2 F.J. 24, 25 (October 2010).

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. Machine v. Fantasy Football League Commissioner, 2 F.J. 1, 2 (September 2010).

Here, the roto league does have a constitution which grants the commissioner the power and authority to rule on pending trades. The criteria for rejecting trades includes collusive conduct or lopsided deals that are detrimental to the league as a whole. However, the constitution fails to provide a definition of collusion.

Collusion is defined as a secret agreement or conspiracy especially for fraudulent or treacherous purposes. See Steel Curtain v. Rusty Trombones, 3 F.J. 201, 203 (November 2011) (holding that a secret agreement between teams to use the first waiver position as a means to move a player to another team further down the list was collusive because its purpose was to circumvent the established rules).

It is quite difficult to prove the existence of collusive conduct without a confession or some form of written proof. No such concrete proof is present in this case. As a result, the Court will rely on circumstantial evidence and weight the totality of the circumstances. John Doe v. Richard Roe, 3. F.J. 197, 200 (October 2011).

When presented with allegations of collusion, the Court will look at the evidence in the light most favorable to the accused. This is because acts of collusion within a fantasy league are one of the most serious fantasy sports crimes that can be committed and can undermine the integrity of a league more so than almost anything else. Team Zero v. Samcro Reaper Crew, 3 F.J. 177, 179 (October 2011); see also John Doe v. Richard Roe, 3. F.J. at 200 (emphasizing how serious an issue it is when teams make individual agreements with each other to circumvent the rules for personal benefit).

The roto league commissioner informed the Court that APK and FOS are casual friends who met through their mutual involvement in the league. They do not have any personal contact with each other outside the confines of the league. While this is not indicative of collusive activity either way, their lack of a close, personal relationship weighs in favor of there being no collusion. See Jetnuts v. Joker’s Wild, 2 F.J. 15, 16 (September 2010) (holding that the fact two league members are close friends is not demonstrative in and of itself of collusion).

It is well established that people who pay to participate in fantasy leagues should be given the freedom to manage their teams accordingly by making trades and transactions. 4 Ponies v. Carson City Cocks, 3 F.J. 13 (May 2011). This includes the freedom and autonomy to choose with whom they would like to engage in trades. Teams are not obligated to shop players around for a more advantageous deal solely to appease skeptical league members. Road Runners v. Urban Achievers, 3 F.J. 47, 50 (June 2011).

If APK was satisfied with the compensation he received in his prior deals with FOS, then he should not be prohibited or scrutinized from making these deals so long as the commissioner deemed them fair and equitable, which he did. If the commissioner had any issues with the compensation being provided by either team, he had the power to reject those trades. Tiger’s Blood v. Hulkamaniacs, 3 F.J. 58, 62 (July 2011).

The commissioner also advised that APK is currently in 10th place while FOS is currently in 4th place. The underlying trade that was made is indicative of the exact type of maneuver that would be made by an unsuccessful team in a keeper league. When a team owner in a keeper league no longer has any hope for contending in the current season, he/she must make a critical roster management decision of whether to trade off established players in exchange for unknown entities in building for the future. See Winners v. Seven Shades of Shite, 3 F.J. 97, 102 (July 2011). APK received top level prospects in the deal which supports this notion.

When looking at the totality of the circumstances and the evidence currently available, there does not appear to be any collusive conduct between APK and FOS. APK’s reasoning for entering into trades with FOS is purely subjective and he is entitled to make those decisions on his own. He is under no obligation to trade with other teams if he does no want to. Further, since there is no dispute over the fairness and equitability of those prior trades, they are both acting within the rules and according to their own fantasy baseball managerial strategies.

It is a shame when these allegations arise within a fantasy league. When a league is tarnished with skepticism and speculation over everyone else’s intentions, it can potentially affect the well-being of the league as a whole. Bald Eagles v. Weasel D, 3 F.J. 205, 210 (November 2011). Here, these allegations are completely unfounded. Based on the foregoing, the Court upholds the commissioner’s decision that no collusive conduct is present between APK and FOS.


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Spot on.  The only way tho could be collusion is if there was an unspoken agreement that a prospect laden trade would be offered if and when situations reverse.  I.e “if you are in contention next year ill return soriano for rizzo”  doesn’t even seem to be a question for me.  In my experience certain ma.agers are highly risk aversre and would obviously be mord comfortable trsding with a friend who they do not think is likely to crush them.  Seems above board to me.  No rules say you have to even your trades out amongst teams


If I was in a league where two people ONLY traded with each other over the course of years, I would have to be totally and utterly convinced there was nothing going on to feel comfortable continuing to play in the league.

If it looks like a duck, and quacks like a duck, it may not be a duck, but I’m assuming it is, and moving on.