In a 16-team Dynasty League, a manager publicly expressed interest in trading future draft picks for a running back or wide receiver. Shortly thereafter, the same manager initiated a trade offering a 2026 second-round pick and a 2027 third-round pick in exchange for a player listed on the Sleeper platform as “T. Etienne.” Both the trading manager and Petitioner-Commissioner approved the transaction believing the player to be Travis Etienne of the Jacksonville Jaguars. Upon execution, all parties discovered the player was in fact Trevor Etienne—Travis’s younger brother, then a rookie with the Carolina Panthers. The mistaken manager admitted the error and sought reversal. The league membership divided evenly on whether to void the trade, and the parties agreed to abide by this Court’s ruling.
We hold that the trade should be partially reversed. The manager receives back Trevor Etienne and the 2026 second-round pick, but forfeits the 2027 third-round pick as punitive damages for his failure to exercise reasonable diligence. This split remedy balances competing principles: correcting an honest mutual mistake while maintaining accountability for roster management in the high-stakes context of dynasty leagues where future draft picks carry substantial value.
I
We begin with the undisputed facts. The manager posted in the group chat that he wanted to trade future draft picks for a running back or receiver. He then initiated a trade proposal sending a 2026 second-round pick and a 2027 third-round pick for “T. Etienne.” The Sleeper platform displays players using first initial, hyphen, and last name—hence “T. Etienne” for both Travis Etienne and Trevor Etienne. The platform also displays team affiliations, which in this case showed “Carolina.”
The manager who initiated the trade believed he was acquiring Travis Etienne, the established Jacksonville Jaguars running back. The manager who accepted the trade believed he was trading away Travis Etienne. The Commissioner, when approving the transaction (the league uses commissioner approval rather than automatic processing), also believed the trade involved Travis Etienne. All three parties operated under the same mistaken belief about the player’s identity.
Only after the trade processed did the parties discover that “T. Etienne” referred to Trevor Etienne—Travis’s younger brother, a rookie with the Carolina Panthers who was drafted in 2025. The mistaken manager immediately admitted his error and sought relief. As the record reflects, “the manager admits it was a mistake” on his end. The league convened to address the matter and split evenly, prompting this petition for declaratory relief.
Before proceeding to our analysis, we address a threshold question of recusal. One Justice acknowledged that he “may have engaged in this sort of activity in the past”—specifically, trading players with similar names in bad faith during middle school fantasy baseball leagues. That Justice properly recused himself from consideration of this case. We commend his recognition that prior bad acts create an appearance of bias that warrants recusal, even where—as here—the factual circumstances differ materially from his own adolescent schemes.
II
This Court has consistently held that commissioners should correct honest mistakes where the manager’s actual intent is clear and the error is immediately reported. In In re: Brown-for-Brown Roster Transaction, 21-1253-1 (2021), a manager accidentally dropped wide receiver Antonio Brown when he intended to drop kicker Josh Brown. We held that “commissioners should enforce the spirit of transactions rather than technicalities, particularly where honest mistakes are immediately apparent.”
The present case extends that principle to the trade context, with an important twist: this is not a case of unilateral mistake where one party erred and the other party knew or should have known of the error. This is a case of mutual mistake—a shared misapprehension of material fact affecting all parties to the transaction. Both the offeror and the acceptor believed they were trading for Travis Etienne. Even the Commissioner, when exercising his approval authority, believed the trade involved Travis Etienne.
Contract law has long recognized mutual mistake as grounds for rescission. Where both parties to an agreement share a mistaken belief about a material fact—particularly about the identity of the subject matter—equity permits voiding the transaction. The Restatement (Second) of Contracts recognizes that “a party’s non-disclosure of a known mistake does not affect the contract” but that “a mistake of both parties … as to a basic assumption on which the contract was made” may warrant avoidance.
The analogy to contract law is instructive. Imagine a buyer who seeks to purchase a painting by Rembrandt, a seller who believes he is selling a Rembrandt painting, and a transaction where both parties discover post-sale that the painting was actually by a lesser-known artist named Rembrandts. The mutual mistake about the identity of the subject matter—which artist created the work—would constitute grounds for rescission. The same principle applies here: both parties believed they were trading for an established NFL running back with proven fantasy value, when in fact they were trading for his rookie brother with minimal track record.
The platform design contributed materially to this confusion. As one Justice observed during oral argument, “why does Sleeper do this” with the abbreviated naming convention? The platform lists both Travis Etienne and Trevor Etienne as “T. Etienne,” creating precisely the confusion that occurred here. This is not dissimilar from the situation in Brown-for-Brown, where “fantasy platforms list players as ‘J. Brown’ and ‘A. Brown,’ creating exactly the confusion that occurred.”
We have held that “when platforms create confusion through abbreviated player listings, and when that confusion leads to obvious errors that managers immediately report, commissioners should correct those errors rather than treating them as binding decisions.” See Brown-for-Brown. The platform’s design choice to abbreviate player names using only the first initial creates foreseeable confusion when siblings play in the NFL. Commissioners should account for this platform flaw when evaluating whether to reverse trades executed under mutual mistake.
III
Having established that mutual mistake generally warrants reversal, we must address whether any circumstances in this case counsel against full relief. Two factors are relevant: (1) the initiating party’s opportunity to discover the error through reasonable diligence, and (2) the high-stakes nature of dynasty league draft picks.
First, the opportunity for discovery. While the Sleeper platform abbreviates player names as “T. Etienne,” it also displays team affiliations. In this case, the platform showed “Carolina”—the Carolina Panthers, Trevor Etienne’s team. As one Justice observed, “it does say Carolina” right there on the screen. A reasonably diligent manager reviewing the trade proposal would have noticed this team designation and questioned why Travis Etienne was listed as playing for Carolina rather than Jacksonville.
This is not to say the manager acted in bad faith. The error was honest—an oversight born of assumption rather than deception. But oversight is nonetheless oversight. The platform provided information sufficient to reveal the error: the team name “Carolina” appeared alongside “T. Etienne.” A manager sending valuable future draft picks in a 16-team dynasty league bears some responsibility to verify that the player he is acquiring is indeed the player he believes he is acquiring. This verification could have taken seconds: clicking on the player name, reviewing his statistics, or simply noticing the team designation.
The record suggests the manager was operating on autopilot, seeing “T. Etienne” and assuming it must be Travis Etienne without reviewing the details. As one Justice remarked, “you’re kind of on autopilot” when reviewing familiar names. But in a dynasty league where future second-round picks carry substantial value, autopilot mode is insufficient. Managers must exercise reasonable diligence when executing trades involving valuable assets.
We distinguished this duty of diligence in Don v. Commissioner, 24-0838-2 (2024), where we held that a manager who failed to verify that a defense transaction had executed correctly was not entitled to retroactive relief. We emphasized that “managers must familiarize themselves with how their platforms operate and verify that transactions execute as intended.” While Don involved platform interface confusion rather than mutual mistake, the principle applies: managers bear responsibility for checking the details of their roster transactions.
The second factor is the high-stakes nature of dynasty league draft picks. In a 16-team dynasty league, a 2026 second-round pick and a 2027 third-round pick represent significant future assets. As one Justice observed, “in a 16-team league, a second-round pick is actually valuable.” These picks can be used to acquire emerging talent, to trade for established players, or to rebuild rosters over multiple seasons. The mistaken manager was trading away two years of draft capital for what he believed would be a reliable running back. Instead, he acquired a rookie with minimal proven production.
This valuation disparity—established starting running back versus unproven rookie—makes the mistake material. No reasonable manager would trade a 2026 second-round pick and a 2027 third-round pick for Trevor Etienne when he could acquire similar production from waiver wire pickups or later-round selections. The trade makes sense only if the acquired player is Travis Etienne. This confirms that the parties’ shared mistake about player identity was material to the transaction.
IV
Having established (1) that mutual mistake warrants reversal, but (2) that the initiating party had opportunity to discover the error through reasonable diligence, we must fashion an appropriate remedy. We reject both extreme positions: full rescission without consequence, and maintaining the trade as executed without relief.
Full rescission would be appropriate if the manager bore no responsibility for the error. But as discussed above, the platform displayed “Carolina” alongside “T. Etienne.” A reasonably diligent manager would have noticed this discrepancy and investigated further. Granting full relief would excuse inattention and create moral hazard—managers could execute trades without carefully reviewing player details, knowing that obvious mutual mistakes would be reversed without penalty.
As we warned in Don v. Commissioner, “if managers can obtain retroactive [relief] whenever platform interfaces operate in unexpected ways—provided only that their intent was clear—the incentive to verify roster moves disappears.” The same concern applies here. If managers can execute trades based on platform abbreviations without checking team designations, player statistics, or other identifying information—and then obtain full rescission when mistakes are discovered—the duty of reasonable diligence becomes toothless.
On the other hand, maintaining the trade as executed would be inequitable given the mutual mistake and the platform’s contribution to the confusion. Contract law permits rescission for mutual mistake precisely because holding parties to contracts based on shared misapprehension of material facts violates principles of fair dealing. As we held in Brown-for-Brown, fantasy football should “prioritize substance over technicality.” The substance here is that all three parties—offeror, acceptor, and Commissioner—believed the trade involved Travis Etienne. Binding the manager to a trade for Trevor Etienne would elevate technicality over the actual meeting of the minds.
We therefore adopt a middle approach: partial rescission with punitive damages. The manager receives back Trevor Etienne and the 2026 second-round pick—the more valuable of the two draft picks he traded away. But he forfeits the 2027 third-round pick, which the accepting party retains as compensation for the disruption and as punishment for the initiating manager’s failure to exercise reasonable diligence.
This remedy serves multiple purposes. First, it corrects the mutual mistake by returning the misidentified player and the most valuable asset traded. The manager is not bound to a trade he never intended to make. Second, it imposes accountability by requiring the manager to forfeit the lesser draft pick. He learns a hard lesson about verifying roster transactions in dynasty leagues. Third, it compensates the accepting party, who acted in good faith, accepted what he believed was a fair trade for Travis Etienne, and now must unwind the transaction through no fault of his own. The retained third-round pick provides some value for his trouble.
Fourth, and critically, this remedy balances the competing principles articulated during oral argument. One Justice initially argued for full reversal based on good faith commissioning: “if I was the commissioner, I would immediately reverse this because it’s obvious the guy’s not going to trade a future second for Trevor Etienne.” Another Justice countered that “it’s on him” because “it says the team” and the manager “should have followed up” before executing the trade. Our holding accommodates both views: the obvious mutual mistake warrants relief, but the duty of diligence requires some penalty.
V
We address several additional points. First, the distinction between this case and bad-faith player-swapping schemes. One recused Justice acknowledged engaging in similar conduct during adolescence—acquiring players with similar names and trading them in bad faith to exploit confusion. Such conduct would be categorically impermissible. See Andrew v. Commissioner, 24-0830-1 (2024) (voiding trade where Commissioner possessed material non-public information and exploited information asymmetry).
The present case is distinguishable because the accepting party did not seek to exploit the confusion. Both parties shared the same mistaken belief. There is no evidence that either party knew or should have known that “T. Etienne” referred to Trevor rather than Travis. This is honest mutual mistake, not deliberate deception. The remedy we adopt—partial rescission—would be inappropriate if either party had acted in bad faith. In such cases, full rescission and potential sanctions would be warranted.
Second, the role of the Commissioner’s mistake. The Commissioner approved this trade believing it involved Travis Etienne. His mistake mirrors the parties’ mistake. Some might argue that the Commissioner’s error should insulate the parties from any penalty—if the Commissioner himself missed the “Carolina” designation, how can we fault the trading parties for the same oversight?
We reject this argument. Commissioners serve as reviewers of trades, checking for collusion or obvious procedural irregularities. They do not—and should not—verify every factual detail of every trade. The Commissioner’s role is to ensure that trades are not collusive, not to serve as quality control for parties’ player evaluations. When the Commissioner approved this trade, he was ensuring that both parties were acting in good faith, not verifying that “T. Etienne” referred to the correct Etienne brother.
The initiating party, by contrast, was executing a trade involving two years of draft picks. He bore primary responsibility for verifying that the player he was acquiring was the player he intended to acquire. The Commissioner’s concurrent mistake does not excuse the initiating party’s failure to exercise reasonable diligence.
Third, the league’s 50-50 split on whether to void the trade. This division reflects reasonable disagreement about how to balance competing principles. Half the league emphasized the mutual mistake and the platform’s contribution to confusion—factors supporting full reversal. The other half emphasized the duty of diligence and the information available on the platform—factors supporting maintaining the trade as executed. Our holding accommodates both positions through the split remedy.
Fourth, the possibility of requiring a team name change as additional sanction. During oral argument, one Justice proposed requiring the manager to “change his team name to like T. Etienne” as a form of public shaming. While creative, we decline to impose this additional sanction. The forfeiture of the 2027 third-round pick provides adequate punishment and deterrence. Further penalties would be disproportionate to the offense, which was honest mistake rather than willful misconduct.
* * *
The Sleeper platform’s abbreviated naming convention created foreseeable confusion, and both parties shared a mistaken belief about the player’s identity. This mutual mistake warrants relief. But the platform also displayed “Carolina” alongside “T. Etienne”—information sufficient to alert a diligent manager that something was amiss. In a 16-team dynasty league where second-round picks carry substantial value, managers must verify the details before execution.
We balance these considerations through a split remedy. The manager receives back Trevor Etienne and the 2026 second-round pick, correcting the mutual mistake. But he forfeits the 2027 third-round pick as punitive damages for his failure to exercise reasonable diligence. This serves the dual purposes of equitable relief and accountability—correcting an honest mistake while imposing consequences for insufficient verification.
As one Justice observed, making the trade stand would be “funnier” but reversing it is “justice.” Justice requires recognizing the mutual mistake that affected all parties, but it also requires accountability for failures of diligence. The split remedy we adopt today serves both purposes.
Trade partially reversed; 2026 second-round pick restored to original owner; 2027 third-round pick forfeited as punitive damages.