Chris’s fantasy league—comprised, as he emphasizes, of forty-year-old fathers—maintains a standing rule requiring any member whose roster produces a zero-point performance from any player to shotgun a beer on video and distribute said video to the league. This past season, Xavier Worthy sustained an injury on the third play of Week One and finished with zero points. Certain league members now argue that the shotgun rule’s purpose is to punish roster management negligence, not injury misfortune, and therefore early-game injuries should be exempt. Other members contend that the plain language admits no exceptions and that injury-based zeros are, if anything, more comedically appropriate for punishment.
We side with the latter camp decisively and unanimously. The rule says “any player” who scores zero points triggers the shotgun requirement. It does not say “any player whose zero results from inattention” or “any player except those injured early in games.” Xavier Worthy scored zero points. The manager must shotgun a beer. As Justice Horlbeck observed with appropriate finality: “Don’t let your league mates be cowards. All zeros count.”
I
The facts require little elaboration. Chris’s league adopted a beer-shotgunning penalty: any manager whose player scores zero points must shotgun a beer and videotape the performance for league distribution. During Week One of the current season, a league member started Xavier Worthy at wide receiver. Worthy was injured on the third play of the game. He finished with zero points.
The league immediately divided on whether the shotgun obligation applied. One faction argued that the rule’s animating purpose is to punish inattention and poor roster management—starting players on bye weeks, forgetting to check injury reports, leaving inactive players in starting lineups. These managers contend that injury-based zeros involve no fault and therefore should not trigger punishment. The opposing faction insisted that the rule’s text is clear, that it contains no exception for injuries, and that creating such an exception would undermine the rule’s effectiveness.
Chris brought the dispute to Fantasy Court seeking declaratory relief on rule interpretation. We granted review to establish whether shotgun-zero rules apply uniformly to all zero-point performances or whether injury-based zeros constitute a special category exempt from punishment.
II
We begin with the rule’s text, which is unambiguous. The league requires shotgun punishment for “any player” who scores zero points. Not “any player whose zero results from negligence.” Not “any player who scores zero due to roster management failures.” Just “any player” who scores zero.
This plain language resolves the case. Xavier Worthy is “any player.” He scored zero points. The punishment applies. If Chris’s league wished to limit the rule to negligence-based zeros while exempting injury-based zeros, it should have written that limitation into the rule. It did not. We will not rewrite league rules to create exceptions that their text does not contain.
We confronted precisely this issue in In re Negative Points Penalty Rule, 24-0826-3 (2024), where a manager argued that his player’s negative two points did not satisfy a “zero points” penalty rule. We rejected that semantic evasion immediately: “A rule penalizing ‘zero points’ naturally encompasses all point values at or below zero. To hold otherwise would require adding language the rule does not contain.” The same principle applies here. A rule penalizing “any player” who scores zero encompasses all zeros—injury-based, negligence-based, and everything in between.
The proponents of an injury exception ask us to interpret “any player” as “any player whose zero results from roster management failure.” That interpretation does not merely clarify ambiguity—it rewrites the rule entirely by adding a fault requirement that appears nowhere in the text. As we emphasized in Negative Points, we “decline to rewrite league rules to create loopholes that no reasonable member would have intended.” The same principle bars us from inserting a negligence requirement where none exists.
III
The injury-exception proponents argue that we should interpret the rule in light of its purpose: punishing inattention and poor roster management. Even accepting that characterization of purpose—which we address below—it does not support creating an injury exception.
Starting a player who gets injured on the third play constitutes a roster management decision subject to second-guessing just like any other. The manager chose to start Xavier Worthy. He could have started someone else. Worthy got injured immediately and produced zero points. That sequence reflects the kind of roster outcome—poor fantasy production from a started player—that shotgun rules exist to address. The fact that the poor production resulted from injury rather than game script or defensive performance does not transform it into a fundamentally different category.
Moreover, the injury-exception theory rests on a false premise: that shotgun-zero rules serve only to punish negligence. They do not. As Justice Kelly explained at length during oral argument, these rules serve multiple interconnected purposes that extend well beyond punishment for inattention.
First, they create stakes for every roster decision and every player performance. Managers monitor all their players more closely—even their fifth wide receiver and backup tight end—because any zero triggers consequences. Justice Kelly captured this perfectly: “It keeps you really engaged with all your players because like I was in the press box sweating fucking T.J. Hockenson not having any catches because I didn’t want to have to shotgun a beer.” That heightened engagement applies equally whether zeros result from injury or other causes.
Second, they generate entertainment value through mild embarrassment and creative performance. Justice Kelly described how league members “always really creative with the way they do it everybody uses like a different weapon of choice in terms of like puncturing the beer like these massive knives to like make the hole.” The resulting videos create shared experiences and inside jokes that bind league members together. Injury-based zeros produce equally entertaining content as negligence-based zeros—arguably more so, given the additional element of comic misfortune.
Third, and most important for purposes of this case, they keep league members connected across geographic distances and life changes. As Justice Kelly observed, shotgun rules represent “one of if not the best ways to keep in touch with your friends as you grow older in life and connect with them and stay connected.” The forty-year-old fathers in Chris’s league face the same challenge: maintaining friendships despite work obligations, family responsibilities, and the general chaos of middle age. Sending shotgun videos to the league creates regular touchpoints that sustain those connections.
All three purposes are served equally—if not more effectively—by injury-based zeros. An early-game injury that produces a zero keeps managers engaged (they must monitor even three-play performances). It generates entertaining content (the cosmic injustice of third-play injuries adds comedic value). And it creates connection opportunities (the resulting shotgun video and league-wide reaction provide social engagement). Creating an injury exception would undermine these purposes by reducing the frequency of shotgun obligations and narrowing the range of circumstances that trigger league-wide content creation.
IV
The injury-exception proponents might invoke our force majeure precedents—cases like In re Fantasy Paternity Leave, 21-1238-1 (2021) and Mitch v. League Member, 24-0850-1 (2024)—to argue that injury constitutes an extraordinary circumstance warranting relief from ordinary obligations. This argument misunderstands the function and scope of force majeure relief in fantasy football.
Force majeure relief addresses situations where extraordinary circumstances beyond a manager’s control prevent him from making necessary roster adjustments. In Paternity Leave, we permitted retroactive lineup substitution where a manager’s wife endured 40-plus hours of labor and a started player was scratched approximately one hour before kickoff. In Mitch, we denied relief where a manager’s phone allegedly malfunctioned on Friday but he made no effort to use alternative means of communication over three days. The unifying principle is that truly extraordinary circumstances that prevent reasonable access to roster management may warrant commissioner discretion to adjust lineups retroactively.
But force majeure relief applies to lineup-setting obligations—decisions that managers must make before games commence and that require active intervention to fulfill. It does not apply to penalty rules triggered by objective performance thresholds after games conclude. The distinction is fundamental.
A manager facing extraordinary circumstances (childbirth, hospitalization, carrier pigeon malfunction) might reasonably be unable to check injury reports, adjust his lineup, or make last-minute substitutions. Force majeure relief addresses those situations by recognizing that lineup-setting obligations sometimes conflict with life obligations and that the latter properly takes precedence.
But shotgun-zero penalties are not lineup-setting obligations. They are consequences triggered by objective results—the point totals that players produce during games. Those results occur independently of the manager’s circumstances. Xavier Worthy got injured on the third play whether the manager was at the hospital, on vacation, or sitting on his couch watching the game. The zero happened. The rule applies.
Moreover, the circumstances the injury-exception proponents describe—early-game injuries—are not circumstances affecting the manager. They are circumstances affecting the player. Force majeure relief addresses extraordinary events in the manager’s life that prevent roster management. It does not address unfortunate events in players’ lives that produce poor fantasy outcomes. If we extended force majeure principles to excuse penalties whenever players suffered misfortune, we would undermine penalty rules entirely. Every zero involves some element of misfortune or poor luck.
V
This brings us to the deepest principle underlying our holding: the role of randomness and unfairness in fantasy football. As Justice Horlbeck observed with characteristic clarity, “The point of fantasy is that it’s random and unfair.” That observation, while perhaps overstated, contains an essential truth that defeats the injury-exception theory.
Fantasy football combines skill and luck in proportions that no one can precisely measure. Skilled managers gain advantages through superior research, waiver wire acumen, and trade negotiations. But luck determines whether the running back you start scores on the one-yard line or gets vultured. Luck determines whether the quarterback you bench throws five touchdowns. And luck determines whether the wide receiver you start gets injured on the third play.
The injury-exception theory attempts to cabin luck and preserve a sphere of “pure” skill-based competition where only negligent decisions trigger negative consequences. But this is a fantasy—pun intended. Starting Xavier Worthy in Week One was a decision that combined research (evaluating his talent and opportunity), prediction (forecasting his usage and production), and ultimately luck (whether he stayed healthy and the game script favored him). The injury on the third play was bad luck. But it was not a categorically different kind of bad luck than starting a player who plays the full game but gets zero targets, or a running back who loses his starting job mid-game, or a quarterback who throws four interceptions and gets benched.
All roster decisions involve luck. Attempting to separate “unlucky but blameless” zeros from “negligent” zeros would require Fantasy Court to adjudicate the precise degree of fault in every zero-point performance. Did the manager adequately research injury history? Did he check weather reports? Did he account for defensive matchups? At what point does incomplete research cross the line from bad luck to negligence? These questions have no principled answers because the fault/luck distinction dissolves under scrutiny.
Shotgun-zero rules wisely avoid this morass by applying objective thresholds. Zero points triggers the obligation regardless of cause. This approach has multiple virtues: it is easy to administer, it treats all managers equally, and it embraces rather than fights against fantasy football’s inherent randomness. As we noted in In re The 69 Points Rule, 25-0709-1 (2025), “creative traditions” that “add an element of chaos, excitement, and humor to every week” enhance league engagement and should be honored rather than undermined through exceptions.
The injury-exception theory would also create perverse incentives and encourage evasion. If early-game injuries excuse shotgun obligations, managers would argue about precisely how “early” an injury must occur. Third play clearly qualifies—but what about the tenth play? The end of the first quarter? Halftime? Any line-drawing would be arbitrary and would invite disputes every time a started player got injured and produced low points. Better to apply the rule uniformly to all zeros and embrace the occasional harsh result as the cost of a simple, enforceable system.
VI
We address finally the specific equities of this case, which strongly favor enforcement. Justice Kelly shared that his own league maintains an identical shotgun-zero rule and that he personally “had to shotgun a beer” after his defense scored zero points following an “11 hour” flight from Ireland, at “six in the morning Ireland time,” when he was “exhausted.” If Justice Kelly must shotgun a beer under those brutal circumstances—after international travel, after a defensive unit’s zero rather than a skill player’s injury, in the middle of the night by his internal clock—then surely Chris’s league member can shotgun a beer after Xavier Worthy’s third-play injury.
The whole point of these rules, as Justice Kelly emphasized, is that they are “not designed to be convenient.” They are designed to be inconvenient, mildly embarrassing, and compelling. They create stakes that keep managers engaged. They generate content that keeps leagues connected. And they apply uniformly to all zeros regardless of circumstance, creating equal treatment and simple administration.
As we held in Negative Points, “Absent specification” of an exception in the rule’s text, “the operative principle is straightforward: rules penalizing poor performance apply with at least equal force to worse performance.” Injury-based zeros are not “worse” than negligence-based zeros in any meaningful sense—they simply reflect a different cause producing the same result. But they are certainly no better. Creating an exception for them would privilege one category of zero over another based on causal distinctions that the rule’s text does not recognize and that serve no legitimate purpose.
Justice Kelly’s colorful phrase captures the essential point: there are “peace signs when someone goes out of a game.” The league reacts to injuries with immediate recognition that a shotgun obligation has been triggered. Far from viewing injury-based zeros as exempt or special, Justice Kelly’s league treats them as particularly entertaining triggers: “It’s actually funnier if it’s Xavier Worthy getting hurt on the third play of the game.” The comic timing of immediate injury followed by required beer consumption generates exactly the kind of memorable league moment that these rules exist to create.
* * *
Chris’s league must hold firm. Xavier Worthy scored zero points on the third play of Week One. The manager who started him must shotgun a beer and send the video to the league. No exceptions for injuries, no exceptions for bad luck, no exceptions for circumstances beyond the manager’s control. The rule says “any player” who scores zero triggers the obligation. Xavier Worthy is any player. He scored zero. The rest is just execution.
We close with the simple wisdom that resolved this case: “Don’t let your league mates be cowards. All zeros count.” Shotgun rules work because they apply uniformly and create stakes for every player on every roster every week. Creating exceptions for injury—or for any other category of “blameless” zero—would undermine that uniformity, invite disputes about causation and fault, and transform a simple entertaining tradition into a complicated adjudicatory system. Chris’s league adopted a bright-line rule: any zero triggers a shotgun. That clarity is a feature, not a bug. Enforce it.
Petition denied. All zeros count. The manager must shotgun a beer.