Petitioner Justice presented to the emergency room at approximately 11:00 PM Wednesday evening suffering from an acute stomach ailment. He remained hospitalized for nine hours, departing at 8:00 AM Thursday morning without sleep. Upon returning home, Petitioner consumed a buttered bagel and immediately collapsed into sleep. He awoke Thursday evening at halftime of the Thursday Night Football game to discover that Josh Palmer remained active in his starting lineup—a player Petitioner had no intention of fielding. Petitioner promptly petitioned his league via group chat for retroactive substitution on medical emergency grounds. The league denied relief, responding curtly: “you have to live with your decisions.” Petitioner now appeals that denial.
We reverse. A nine-hour overnight hospitalization for an acute medical emergency constitutes the kind of extraordinary circumstance that warrants retroactive roster relief. While Petitioner had approximately twelve hours between hospital discharge and kickoff to adjust his lineup, the physical and mental exhaustion following a sleepless emergency room visit provides reasonable explanation for his failure to do so. The league’s blanket invocation of personal responsibility—”you have to live with your decisions”—improperly treats a genuine medical emergency as equivalent to routine roster mismanagement. We hold that commissioners must accommodate such circumstances, particularly where the affected manager acted promptly upon discovering the error and where the league operates as a competitive but not ultra-high-stakes environment.
I
We begin with the facts, which largely speak for themselves. Petitioner went to the emergency room at 11:00 PM on Wednesday night with what he described as “a bizarre stomach issue.” He remained there for nine hours—from 11:00 PM Wednesday until 8:00 AM Thursday morning. The record does not indicate that Petitioner slept during this hospitalization; emergency rooms are not known for facilitating restful sleep, and the nature of his treatment presumably required ongoing attention from medical personnel.
Petitioner departed the hospital Thursday morning at 8:00 AM, having been awake for approximately 24 hours or more. He returned home, ate a buttered bagel “easy on the stomach,” and promptly fell asleep. He did not wake until Thursday evening at halftime of the Thursday Night Football game, which kicked off at 8:15 PM Eastern. By that time, Josh Palmer had already played the first half and remained in Petitioner’s starting lineup.
Upon discovering this situation, Petitioner immediately contacted his league via group chat requesting retroactive substitution. The league responded with stark finality: “you have to live with your decisions.” Petitioner brings this appeal, arguing that a nine-hour emergency room visit followed by exhaustion-induced sleep through kickoff constitutes extraordinary circumstances warranting relief.
II
This case requires us to apply the force majeure framework established in In re Fantasy Paternity Leave, 21-1238-1 (2021). In that landmark opinion, we held that commissioners may provide retroactive lineup relief for truly extraordinary circumstances where three conditions are satisfied: (1) the circumstances were genuinely extraordinary and unforeseeable; (2) the affected manager acted reasonably under those circumstances; and (3) granting relief would not create moral hazard by encouraging similar conduct in the future.
We granted relief in Paternity Leave where a manager’s wife endured over 40 hours of labor culminating in their child’s birth, and a late injury scratch left the father with zero points at quarterback. We emphasized that “some circumstances transcend the ordinary competitive expectations that govern roster management” and that “the birth of a child represents precisely the kind of extraordinary life event that warrants commissioner discretion to provide emergency relief.”
Since Paternity Leave, we have applied this framework consistently. In Eber v. Commissioner, 21-1215-1 (2021), we granted relief where ESPN’s platform technicality locked a manager’s entire roster and the manager contacted his league Sunday morning before games commenced. In Isaac v. Commissioner, 24-0858-1 (2024), we denied relief where a manager failed to monitor injury news during a 90-minute window before Monday Night Football despite having checked his lineup earlier in the day. In Mitch v. League Member, 24-0850-1 (2024), we denied relief where a manager’s phone allegedly malfunctioned on Friday but the manager had three full days to utilize alternative means and contacted the league only after discovering he had lost his matchup.
The present case falls between these precedents. It involves more compelling circumstances than the phone malfunction in Mitch or the injury monitoring lapse in Isaac, but less obviously extraordinary circumstances than childbirth in Paternity Leave or the platform lock in Eber. Let us apply the three-factor test to determine where relief is warranted.
III
The first factor examines whether the circumstances were truly extraordinary and unforeseeable. We hold they were. A nine-hour overnight hospitalization for an acute medical emergency is not a routine inconvenience. Emergency rooms treat serious medical conditions requiring urgent care. The fact that Petitioner presented at 11:00 PM and remained until 8:00 AM the following morning—through the entire night—demonstrates the severity of the situation. This was not a brief clinic visit or a scheduled procedure that Petitioner could have anticipated and planned around. This was an unforeseeable medical emergency that consumed nine hours of his night.
We distinguish this case from Mitch, where the claimed equipment malfunction occurred on Friday and the manager had three full days to find alternative means of accessing his lineup. In Mitch, we emphasized that “a phone malfunction, while inconvenient, ranks among the most ordinary technical difficulties modern fantasy managers face” and that the manager “had 72 hours to address the problem.” Here, Petitioner faced not a technical difficulty but a medical emergency, and he had only twelve hours rather than three days.
We also distinguish this case from Isaac, where the manager simply failed to monitor injury news during a 90-minute window despite being available to do so. In Isaac, we held that “routine injury monitoring during a high-stakes game does not constitute the kind of extraordinary circumstance that warrants retroactive roster relief.” Here, Petitioner was not routinely monitoring injury news—he was in an emergency room receiving medical treatment.
The more difficult comparison is to Paternity Leave, where the manager’s wife was in active labor during the fantasy weekend. Childbirth is undoubtedly more momentous than a stomach ailment, and active labor creates an ongoing emergency that directly conflicts with fantasy football obligations. But we decline to establish a hierarchy of medical emergencies where only the most profound qualify for relief. A nine-hour emergency room visit is sufficiently extraordinary to warrant accommodation, even if it does not rise to the significance of welcoming a child into the world.
We acknowledge the league’s potential concern, raised during our deliberations, about whether the medical emergency was “self-inflicted.” If Petitioner went to the emergency room due to reckless conduct—excessive alcohol consumption, dangerous activities, or similar choices—should that affect our analysis? We hold it does not, at least on this record. First, Petitioner described “a bizarre stomach issue,” which suggests a medical condition rather than behavioral consequences. Second, even self-inflicted injuries requiring emergency room treatment are sufficiently serious to warrant accommodation—we do not condition relief on judgments about how the medical emergency arose. Third, the timing of the hospitalization (11:00 PM Wednesday through 8:00 AM Thursday) does not suggest intoxication or similar self-inflicted circumstances that might arise from Thursday night activities.
The extraordinary nature of the circumstances is confirmed by comparison to routine excuses for roster mismanagement. Managers cannot claim relief because they forgot to check their lineups, because work meetings interfered, because they were traveling without wi-fi, or because they prioritized other activities over fantasy football. See Isaac; Mitch. But a nine-hour emergency room visit is categorically different from these routine inconveniences. It represents a genuine medical crisis that consumed Petitioner’s entire night and left him exhausted.
IV
The second factor asks whether Petitioner acted reasonably under the circumstances. This presents the closest question in the case. Petitioner left the hospital at 8:00 AM Thursday and kickoff occurred at 8:15 PM Thursday—a span of approximately twelve hours. During that window, Petitioner could theoretically have checked his lineup before falling asleep or set an alarm to wake before kickoff. His failure to do either raises questions about whether he acted with the diligence we require for emergency relief.
We hold, however, that Petitioner’s conduct was reasonable under the specific circumstances he faced. He had been awake all night in an emergency room receiving medical treatment for nine hours. He returned home at 8:00 AM Thursday morning physically and mentally exhausted. The fact that he ate a bagel and immediately fell asleep—sleeping through the entire day and into halftime of the evening game—demonstrates the severity of his exhaustion. This was not a manager who casually napped through kickoff. This was a manager who collapsed into unconsciousness after a medical ordeal.
We draw a critical distinction between Petitioner’s circumstances and those in Mitch and Isaac. In Mitch, we established the “alternative means doctrine,” holding that “when a manager faces equipment failure or other technical obstacles that prevent direct access to his lineup, he must demonstrate reasonable efforts to utilize alternative means before seeking extraordinary retroactive relief.” The manager in Mitch made no effort to contact anyone through any channel for three full days, suggesting that the claimed phone malfunction did not genuinely prevent lineup access. Here, Petitioner was not prevented by equipment failure but by physical collapse following medical trauma. There were no “alternative means” available to someone who had fallen into exhaustion-induced sleep.
Similarly, in Isaac, we held that a manager who “fails to monitor injury developments during the 90-minute window preceding Monday Night Football kickoff” despite having “checked his lineup earlier in the day” and having “access to widely available injury alert systems” acted unreasonably. But Petitioner did not fail to monitor injury developments—he was unconscious. And unlike the manager in Isaac, who had checked his lineup earlier and simply failed to continue monitoring, Petitioner never had an opportunity to address his lineup after the medical emergency arose.
The timing of Thursday Night Football compounds the difficulty of Petitioner’s situation. Had this been a Sunday slate of games, Petitioner would have had until 1:00 PM Eastern Sunday to wake, recover, and adjust his lineup—a full day and a half after hospital discharge. But Thursday Night Football kicks off at 8:15 PM the same day, giving managers in Petitioner’s situation only twelve hours. When those twelve hours follow a nine-hour overnight hospitalization without sleep, it is reasonable that a manager might collapse into extended sleep rather than check his fantasy lineup before resting.
We emphasize what Petitioner did not do. He did not wait to see how Josh Palmer performed before requesting relief. He did not contact the league only after discovering an unfavorable result. He “promptly” contacted his league upon waking at halftime, as soon as he discovered the error. This demonstrates good faith rather than outcome-oriented gamesmanship. As we observed in Eber, managers seeking relief must act “with reasonable diligence by designating desired changes before games begin” or, when that proves impossible, as promptly as circumstances permit. Petitioner acted as promptly as his medical situation allowed.
V
The third factor considers whether granting relief would create moral hazard. We hold it would not, at least not to a problematic degree. Unlike the phone malfunction in Mitch—which “every manager who faces a close Monday night matchup” could claim to avoid unfavorable results—emergency room hospitalizations cannot be fabricated or strategically timed. Managers do not fake nine-hour overnight emergency room visits to excuse roster mismanagement. The verification mechanisms available to commissioners (requesting documentation if skeptical) provide adequate protection against fraudulent claims.
We acknowledge the more difficult question of scope: if we grant relief for a nine-hour emergency room visit, must we also grant relief for a six-hour visit? A three-hour urgent care appointment? A severe migraine that prevents checking one’s phone? We decline to establish bright-line rules for every conceivable medical scenario. Instead, we hold that commissioners must exercise judgment in assessing whether claimed medical circumstances are genuinely extraordinary and whether the affected manager’s conduct was reasonable given those circumstances.
The limiting principle here is the overnight hospitalization spanning nine hours immediately before Thursday Night Football. This is not a manager who felt ill on Wednesday afternoon and chose to go to bed early, then slept through Thursday kickoff. This is a manager who spent the entire night in an emergency room and collapsed into sleep upon returning home. That specific combination of circumstances—the extended duration, the overnight timing, the immediate proximity to game day, and the physical exhaustion following discharge—satisfies our standard for extraordinary circumstances without opening floodgates to routine medical excuses.
As we emphasized in Paternity Leave, “emergency relief for extraordinary circumstances does not open floodgates to routine accommodations.” The limiting principles we establish ensure that relief remains “genuinely exceptional.” Here, a nine-hour overnight emergency room visit immediately preceding Thursday Night Football, followed by exhaustion-induced sleep through kickoff, qualifies as genuinely exceptional. Managers who miss Sunday games after Thursday medical appointments, or who sleep through kickoff after routine Friday evening activities, or who claim illness without corroborating evidence, will not satisfy this standard.
VI
We turn finally to the league’s response: “you have to live with your decisions.” This framing mischaracterizes what occurred. Petitioner did not make a “decision” to start Josh Palmer. He made a decision to go to the emergency room when facing an acute medical emergency—the correct decision. He made a decision to sleep when exhausted after nine hours of overnight hospitalization—also the correct decision. What he did not do is make an affirmative choice about his fantasy lineup during the twelve-hour window between hospital discharge and kickoff. The league’s response treats this omission as equivalent to a deliberate roster choice. It is not.
We emphasized in Paternity Leave that “fantasy football should enhance life, not diminish it by demanding attention during life’s most significant moments.” The same principle applies to medical emergencies. Fantasy football should not require managers to prioritize lineup adjustments over sleep following overnight hospitalizations. The league’s rigid invocation of personal responsibility—suggesting that Petitioner should have checked his lineup before collapsing into exhaustion—reflects a vision of fantasy football that we decline to mandate.
This case also implicates the distinction we drew in Paternity Leave between “civil” leagues and “criminal” leagues—between friendly competitions with modest stakes and high-stakes money leagues where substantial buy-ins create significant financial consequences. Nothing in the record suggests this league operates at the high-stakes end of that spectrum. In such leagues, “basic human decency should prevail over rigid technicality.” The league’s refusal to accommodate a nine-hour emergency room visit followed by exhaustion-induced sleep reflects an approach to fantasy football that prioritizes rules over reasonableness.
During our deliberations, one of us compared the inconvenience of living on the West Coast—where London games kick off at 6:00 AM and require early wake-up times to adjust lineups—to spending nine hours in an emergency room. This comparison, while offered somewhat in jest, illuminates the problem with the league’s position. Geographic residence is a choice; acute medical emergencies are not. Managers who live on the West Coast accept the burden of early-morning roster management. Managers who go to emergency rooms do not accept similar burdens as part of their fantasy football obligations.
VII
We address one final concern raised during deliberations: the absence of detailed medical information. We do not know the precise nature of Petitioner’s “bizarre stomach issue.” We do not know whether it required treatment, observation, or simply waiting for test results. We do not know whether it was life-threatening or merely severely uncomfortable. Should this uncertainty affect our analysis?
We hold it should not. Petitioner presented to an emergency room at 11:00 PM and remained for nine hours. Emergency rooms do not keep patients overnight for minor ailments. The duration of the hospitalization itself demonstrates sufficient severity to warrant accommodation. While we might request medical documentation if presented with a claim that seemed suspicious or fraudulent, nothing about this case raises such concerns. The overnight timing, the nine-hour duration, and the exhaustion-induced sleep through kickoff all support Petitioner’s account.
Moreover, requiring commissioners to evaluate the medical severity of claimed emergencies would place them in an impossible position. Commissioners are not doctors. They cannot assess whether a particular stomach ailment justified nine hours of emergency room treatment. They cannot determine whether alternative conditions might have warranted different treatment. The workable standard is the one we adopt today: extended hospitalizations immediately preceding game day qualify as extraordinary circumstances, and commissioners may request documentation if claims appear suspicious but should generally accept good-faith representations about medical emergencies.
As one of us observed with appropriate humor during deliberations, we could “subpoena” Petitioner’s “healthcare records, login, social security numbers” to verify every detail of his medical treatment. But fantasy football is not a court of law, and commissioners are not judges weighing evidence beyond reasonable doubt. The standard for emergency relief is reasonable belief that extraordinary circumstances genuinely prevented lineup management, not absolute certainty about every medical detail.
* * *
Petitioner went to the emergency room Wednesday night at 11:00 PM with an acute stomach issue. He remained there for nine hours, until 8:00 AM Thursday morning, without sleep. He returned home exhausted, ate a bagel, and collapsed into sleep. He woke at halftime of Thursday Night Football to discover Josh Palmer still in his lineup. His league responded to his request for relief by invoking personal responsibility: “you have to live with your decisions.”
But Petitioner did live with his decisions. He made the right decision to seek emergency medical treatment when facing a serious stomach ailment. He made the right decision to rest after nine sleepless hours in a hospital. What his league demands is that he should have made a different decision—that he should have checked his fantasy lineup before collapsing into sleep, or that he should have set an alarm to wake before kickoff, or that he should have prioritized fantasy football over physical recovery. Those demands are unreasonable.
We hold that nine-hour overnight emergency room hospitalizations immediately preceding Thursday Night Football constitute extraordinary circumstances warranting retroactive roster relief. We hold that collapsing into exhaustion-induced sleep after such hospitalization represents reasonable conduct rather than negligence. We hold that leagues should accommodate such medical emergencies rather than rigidly enforcing rules designed for ordinary circumstances. And we hold that the league’s blanket invocation of personal responsibility—”you have to live with your decisions”—improperly treats genuine medical crisis as equivalent to routine roster mismanagement.
The petition is granted. The league should permit retroactive substitution. And Petitioner should be advised that his league, while presumably composed of good people, needs to reconsider its approach to emergency accommodation. Fantasy football is entertainment, not a test of devotion that requires lineup management following overnight hospitalizations.
Relief granted. Retroactive substitution permitted.