In re Roster Management During Wife’s Labor (2025)

No. 25-0702-2
Joe Flacco Traded to Cincy, Players You Want to Bench, Fantasy Court, and Heifetz Explains Childbirth (October 8, 2025)
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Procedural Posture: Original petition seeking advisory opinion on permissibility of proposed conduct
Held: Threatening to disclose a league member’s conduct to his spouse in exchange for favorable trade consideration constitutes blackmail. Such coercion violates fundamental principles of fair dealing and may not be used to extract fantasy football value.
Justice Kelly delivered the opinion for a unanimous Court.

Petitioner’s sister went into labor with her second child. While Petitioner and his wife assumed childcare responsibilities for the couple’s first child, Petitioner’s sister and her husband (Petitioner’s brother-in-law) proceeded to the hospital. At 4:23 PM, Petitioner observed through the fantasy application that his brother-in-law had executed multiple roster transactions, adding a new defense and a replacement wide receiver. The baby was born at 4:30 PM—seven to twelve minutes after the roster moves were completed. When Petitioner mentioned this timeline to his wife, she became immediately and intensely furious, as Petitioner’s sister is known to harbor passionate animosity toward both fantasy football generally and her husband’s phone usage specifically. Petitioner now seeks a declaratory ruling that he may leverage this information to extract favorable trade consideration from his brother-in-law in exchange for his silence, acknowledging that disclosure to his sister could result in severe marital consequences, potentially including divorce.

We hold that he may not. Threatening to disclose a league member’s conduct to his spouse in exchange for favorable trade consideration violates fundamental principles of fair dealing. While fantasy football tolerates—indeed, celebrates—various forms of gamesmanship and competitive ruthlessness, it does not permit threats that weaponize relationships outside the league to extract fantasy value. That crosses the line from permissible information advantage into impermissible extortion.

I

The factual record is undisputed. Petitioner’s brother-in-law made roster moves at 4:23 PM on the day his second child was born. His wife delivered seven to twelve minutes later, at 4:30 PM. Petitioner learned of this timeline and—in what he himself acknowledges was a failure of judgment—mentioned it to his own wife, who reacted with understandable dismay. Petitioner now contemplates whether he may use this information as leverage in fantasy football trade negotiations, threatening to disclose the timeline to his sister unless his brother-in-law provides “a first round pick or a star player or something really valuable.”

Petitioner’s question is straightforward: “is blackmail legal in the eyes of fantasy court?” The answer is equally straightforward: no. As one host stated with admirable brevity during oral argument, this is a “very funny story, but no.” We agree with both the humor and the holding.

II

We have long recognized a distinction between (1) permissible information-based advantages, and (2) impermissible coercion through threats directed at interests beyond the fantasy league itself. The former category includes advantages arising from superior research, diligent attention to injury reports, or even fortuitous timing—trading away a player before injury news breaks, claiming a handcuff before a starter goes down, or exploiting another manager’s failure to monitor depth chart changes. These advantages operate within the fantasy football system and reflect the competitive skills that make roster management meaningful.

The latter category involves using threats or inducements that operate outside the fantasy football system to manipulate outcomes. In Commissioner v. Danny, 21-1234-1 (2021), we held that offering beer—material compensation outside the fantasy football system—to induce other managers to claim waiver wire defenses constituted impermissible collusion. We emphasized that “fantasy football operates as a closed competitive system where managers make decisions based on factors internal to the competition,” and that “when managers introduce external inducements… they distort the competitive equilibrium by giving some managers access to resources unavailable to others.”

Similarly, in Dave v. Joe, 21-1223-2 (2021), we voided a trade where one manager received a player in exchange for benching his entire starting lineup. We established a categorical rule that “lineup decisions may not be transacted for consideration,” explaining that while “managers retain discretion to field suboptimal lineups in pursuit of their own strategic interests, they may not exchange roster spots or starting lineup decisions for players, draft picks, or any other consideration.”

These cases establish a governing principle: fantasy managers may not introduce considerations external to the fantasy football system to secure competitive advantages. Whether those external considerations take the form of beer, lineup manipulation for payment, or—as here—threats to damage a league member’s marriage, they distort competitive equilibrium in ways our precedents prohibit.

III

Petitioner’s proposed conduct falls squarely within the prohibited category. He seeks to extract trade value by threatening to disclose information to his sister that could cause severe marital discord, potentially including divorce. This threat operates entirely outside the fantasy football system. It leverages Petitioner’s familial relationship and his brother-in-law’s understandable desire to avoid catastrophic marital consequences. It has nothing to do with player evaluation, roster construction, or the competitive skills that fantasy football rewards.

Moreover, the threat targets interests far more significant than fantasy football itself. In Commissioner v. Danny, the external inducement was beer—a relatively minor consideration. Here, the threat is to a marriage. Petitioner himself acknowledges that his sister might “divorce” his brother-in-law if she learns the truth. Threatening to destroy a marriage to acquire Travis Kelce or Ja’Marr Chase represents a grotesque disproportion between the stakes of fantasy football competition and the real-world consequences Petitioner seeks to weaponize.

We acknowledge one host’s observation that the brother-in-law “honestly like trying to like make money for his for his two kids” through his fantasy roster moves. There is dark humor in the proposition that managing one’s fantasy lineup during childbirth constitutes providing for one’s family. But whether the brother-in-law’s conduct was admirable, foolish, or merely understandable is not the question before us. The question is whether Petitioner may threaten to disclose that conduct in exchange for fantasy football assets. He may not.

IV

We distinguish this case from situations involving permissible information advantages. Fantasy managers routinely possess information that other managers lack. A manager who diligently monitors injury reports may learn of a questionable designation before other league members and act accordingly. A manager who studies depth charts may recognize a backup’s increased value before others notice. A manager who follows beat reporters on social media may learn of role changes or opportunities ahead of the market. These information advantages are permissible—indeed, they are the essence of successful fantasy management.

The critical distinction is that these advantages arise from competitive skills internal to fantasy football: research, attention, and football knowledge. They do not involve threats directed at interests outside the league. A manager who trades away a player before injury news becomes public has not threatened anyone. A manager who claims a handcuff before the starter’s injury is announced has not coerced anyone. They have simply acted on information more quickly or recognized opportunities more clearly than their competitors.

Petitioner’s proposed conduct is fundamentally different. He does not seek to trade based on superior information about player values. He seeks to trade based on the threat that he will disclose embarrassing information to a family member, potentially destroying a marriage. The “value” he offers his brother-in-law is not a player or a draft pick—it is silence. And the consideration he demands is not paid willingly as part of a negotiated exchange, but extorted under threat of marital catastrophe.

This distinction tracks the analysis in Andrew v. Commissioner, 24-0830-1 (2024), where we addressed the “implied covenant of good faith and fair dealing” that undergirds all fantasy football competition. We held that certain conduct, while perhaps not technically prohibited by written rules, “offends basic fairness” and violates the implied covenant. Blackmail offends basic fairness. It violates the implied covenant. And it may not be used to acquire fantasy football assets.

V

Having established that Petitioner may not blackmail his brother-in-law, we turn briefly to Petitioner’s more fundamental error: telling his wife in the first place. As one host emphasized, Petitioner should “protect the sanctity of the league” and “protect the shield.” Another host was even more direct: “I have a bigger issue with Redacted for squealing like a little rat.”

We agree with this assessment. Petitioner’s brother-in-law made roster moves during his wife’s labor. Whether this reflects misplaced priorities, nervous energy during a stressful situation, or simply a moment of poor judgment, it is conduct between the brother-in-law and his wife. Petitioner had no obligation—and indeed, no right—to involve himself by reporting this information to his wife, who predictably shared it with or will share it with her sister.

The hosts suggested that once Petitioner told his wife, the information became uncontainable: “His wife is going to squeal.” We suspect this is correct. Petitioner “wasn’t thinking when he said that out loud.” He cannot now put this particular genie back in the bottle. His sister will likely learn the truth regardless of whether Petitioner successfully blackmails his brother-in-law. This makes Petitioner’s proposed scheme not merely impermissible but also futile.

Indeed, Petitioner faces a predicament of his own making. By telling his wife, he has set in motion events that will likely result in his brother-in-law facing marital consequences regardless of whether any trades are executed. Petitioner cannot now monetize information he has already disclosed to someone who will transmit it onward. This is not merely a legal problem but a practical one: you cannot sell silence after you have already spoken.

VI

We pause to consider the brother-in-law’s conduct on the day of his child’s birth. The hosts debated this at length, and we find their discussion instructive. One host observed: “the optics aren’t great it doesn’t look good.” Another asked: “how are you on your phone and like what is going on 17 minutes before” the baby is born?

We acknowledge the optics are indeed not great. Managing one’s fantasy roster during the final minutes before one’s child is born reflects priorities that many would question. The hosts speculated about the logistics: was the brother-in-law “hidden behind like the gown or something down ready to catch the baby” while on his phone? Was he “just like underneath the bed” making moves? These images are both absurd and uncomfortably plausible.

But we note several mitigating factors. First, labor can be prolonged, and the early stages may involve significant waiting with limited ability to provide direct assistance. The hosts acknowledged that “when like the process starts it’s not necessarily like the panic to run to the hospital whatever and it can take like a long time.” Second, the brother-in-law made “nothing shady, nothing nefarious, just added a new defense, got a replacement receiver.” These were routine roster management moves, not evidence of fantasy football addiction requiring intervention.

Third, and most significantly, the brother-in-law made objectively sound roster decisions: he dropped the Texans defense and claimed the Ravens defense, a move that likely won him his matchup that week. One host observed, with tongue firmly in cheek, that the brother-in-law was trying to make money for his two kids. While we treat this observation with appropriate levity, it reflects a truth: fantasy football provides entertainment and, in some leagues, meaningful financial stakes that managers may rationally prioritize even during significant life events.

We compared this case during oral argument to In re Fantasy Paternity Leave, 21-1238-1 (2021), where we held that a manager whose child was born during the fantasy weekend warranted relief for failing to adjust his lineup during 40-plus hours of labor. We emphasized there that “NFL players miss actual games—real, consequential professional football games—for the births of their children. If the NFL accommodates paternity leave, fantasy football leagues can accommodate it too.”

The present case is different. Here, the brother-in-law did not fail to manage his roster—he managed it perhaps too attentively. He does not seek relief from this Court. He seeks only to avoid having his wife learn that he was on his phone making roster moves seven to twelve minutes before their child was born. This is not a fantasy football problem requiring our intervention. This is a marital problem that he must navigate himself, without the threat of blackmail from his brother-in-law distorting his decision-making.

* * *

Petitioner asks what he should do with this information. The answer is simple: nothing. Say nothing further to anyone. Do not use it in trade negotiations. Do not attempt to monetize your brother-in-law’s poor judgment. If your wife has already told your sister or will inevitably do so, that is a family matter to be resolved through family channels, not through fantasy football blackmail schemes.

Fantasy football thrives on information advantages, creative gamesmanship, and competitive ruthlessness. But there is a line between exploiting information about player values and threatening to destroy a marriage. Petitioner crossed that line when he considered blackmailing his brother-in-law for “a first round pick or a star player.” Some advantages, even when they fall into your lap, may not be exploited. Protect the shield. Keep your mouth shut. And under no circumstances may you extract fantasy football value through threats to disclose embarrassing information to family members.

Petition denied.

Cite as: In re Roster Management During Wife’s Labor, No. 25-0702-2 (2025)
Topics
blackmailcorrupt dealingconflicts of interestethicsmarital relations