Petitioner resides in Denmark and could not attend the league draft due to time zone constraints. Understanding the difficulty his absence would create, Petitioner provided the Commissioner with detailed written instructions for each round, including a specific request to draft Emeka Egbuka in the fifth round. When the fifth round arrived, the Commissioner announced to the league that Petitioner wanted “the best available receiver” and selected Jalen Waddle on Petitioner’s behalf. The Commissioner made no mention whatsoever of the explicit written instruction to draft Egbuka.
In the subsequent round, the Commissioner selected Egbuka for his own team.
The Commissioner repeated this conduct with Rashee Rice and Matthew Golden, systematically acquiring for himself players that Petitioner had specifically requested in writing. When confronted, the Commissioner maintains he acted properly and refuses to effectuate any player swaps. Petitioner seeks mandamus to compel the swaps and requests extraordinary relief in the form of retroactive point adjustments for Week 1.
We hold that the Commissioner’s conduct constitutes textbook self-dealing and abuse of power. This is not a close case. This is not a matter requiring careful balancing of competing interests. This is, as the hosts aptly termed it, “black and white.” The Commissioner must immediately swap all affected players. And where the Commissioner’s misconduct caused Petitioner to lose a Week 1 matchup he would have won absent the malfeasance, retroactive scoring adjustments are appropriate.
I
The factual record reveals systematic misconduct. Petitioner—attempting to participate in his league despite living across the Atlantic Ocean—sent the Commissioner detailed written instructions. These were not vague preferences or general guidelines. They identified specific players by name for specific rounds. Round five: Emeka Egbuka. Later rounds: Rashee Rice and Matthew Golden.
The Commissioner ignored these instructions entirely. When the fifth round arrived, he announced that Petitioner wanted “the best available receiver.” This was a lie. Petitioner had not requested the best available receiver. Petitioner had requested Emeka Egbuka. The Commissioner selected Jalen Waddle instead, making no mention of the specific written instruction he had received and was deliberately disregarding.
The next round, the Commissioner drafted Egbuka for himself.
Let us be clear about what happened. The Commissioner possessed written instructions identifying Egbuka by name as Petitioner’s desired fifth-round selection. The Commissioner announced something different to the league—that Petitioner wanted “the best available receiver”—thereby concealing the specific instruction he had received. The Commissioner then selected a different player for Petitioner. And in the very next round, the Commissioner acquired the player Petitioner had specifically requested, adding him to the Commissioner’s own roster.
This was not an isolated mistake. This was not a good-faith misunderstanding. The Commissioner repeated this exact pattern with Rashee Rice and Matthew Golden—systematically ignoring Petitioner’s written instructions and acquiring the specifically requested players for himself. As one host observed, this is “a clever crime” but a crime nonetheless. The Commissioner exploited his position to redirect valuable assets from an absent league member’s roster to his own.
II
We have stated repeatedly that commissioners occupy fiduciary positions requiring heightened duties of good faith and fair dealing. See Andrew v. Commissioner, 24-0830-1 (2024); Andrew v. Commissioner, 24-0826-1 (2024); Josh v. Commissioner, 22-1135-1 (2022). Commissioners may not exploit their administrative access to benefit themselves at their leagues’ expense. They may not engage in self-dealing. And critically, commissioners may not exploit informational advantages—knowledge unavailable to other league members—when executing trades or managing rosters that affect their own competitive interests.
In Andrew v. Commissioner, 24-0830-1 (2024), we voided a trade where a Commissioner executed a transaction with his father-in-law hours after one player sustained a potentially season-ending injury. We held that “commissioners occupy fiduciary positions requiring heightened obligations of good faith and fair dealing” and that “commissioners may not exploit information asymmetries or familial relationships when executing trades that appear to ordinary league members as conflicts of interest requiring intervention.”
In Andrew v. Commissioner, 24-0826-1 (2024), we voided a trade where a Commissioner unilaterally introduced future draft pick trading in a thirteen-year redraft league and immediately used that innovation to acquire Saquon Barkley for himself. We held that commissioners “may not exploit the absence of written prohibitions to introduce unprecedented mechanisms benefiting themselves” and that such conduct “violates the duty of good faith and fair dealing that undergirds all fantasy football competition.”
The Commissioner here violated these principles in the most egregious manner imaginable. He possessed information unavailable to the rest of the league: Petitioner’s detailed written instructions identifying specific players by name. The Commissioner exploited that informational advantage by misrepresenting Petitioner’s instructions to the league, selecting different players for Petitioner, and then acquiring the specifically requested players for himself. This is self-dealing in its purest form—using privileged access to private information to redirect assets from another league member’s roster to one’s own.
Consider what this means. Petitioner, sitting in Denmark and unable to attend the draft, relied entirely on the Commissioner to execute his instructions faithfully. The Commissioner occupied a position of complete trust. Petitioner had no way to monitor the draft in real time, no ability to intervene if problems arose, no recourse beyond trusting that the Commissioner would honor the detailed written instructions he had provided. The Commissioner betrayed that trust systematically and deliberately, round after round.
III
The Commissioner’s refusal to effectuate player swaps compounds his misconduct. When confronted with evidence of his systematic self-dealing, the Commissioner maintains he “did nothing wrong” and refuses to remedy the situation. This position is untenable. As one host observed, the Commissioner is “an idiot” for taking this stance, because “this guy’s in Denmark and trying to be in your fantasy league” and the Commissioner’s conduct amounts to telling him “what the fuck you might as well quit.”
The Commissioner’s argument appears to be that he exercised his discretion in interpreting Petitioner’s instructions and selected players he believed better served Petitioner’s interests. This defense fails for multiple reasons. First, Petitioner’s instructions were explicit. They identified players by name. There was no ambiguity requiring interpretation. “Emeka Egbuka” does not mean “the best available receiver.” It means Emeka Egbuka.
Second, even if the instructions had been ambiguous—which they were not—the Commissioner’s subsequent conduct reveals his true motives. He did not select Waddle because he genuinely believed Waddle better served Petitioner’s interests. He selected Waddle because he wanted Egbuka for himself, as evidenced by his drafting Egbuka in the very next round. The pattern repeated with Rice and Golden. This was not good-faith discretionary judgment. This was systematic acquisition of assets Petitioner had identified as valuable.
Third, the Commissioner’s refusal to remedy the situation demonstrates bad faith. In Andrew v. Commissioner, 24-0826-1 (2024), we observed that commissioners who abuse their power often “believe they can do ‘whatever the fuck [they want]’ simply because they hold executive authority.” We emphasized that commissioners “are not dictators” but rather “fiduciaries who owe duties of good faith and fair dealing to every member of their leagues.” The Commissioner here, like the commissioner in that case, fundamentally misunderstands what his position entails. He occupies a position of trust, not a license to ignore explicit instructions and redirect assets to himself.
IV
The remedy is straightforward: immediate player swaps. Waddle for Egbuka. And swaps for Rice and Golden as well, restoring to Petitioner the players he specifically requested and removing from the Commissioner’s roster the players he improperly acquired through exploitation of his fiduciary position.
But we go further. Where the Commissioner’s misconduct directly caused Petitioner to lose a Week 1 matchup, retroactive scoring adjustments are appropriate. As one host observed, “because the commissioner did it i kind of think of buka’s points last week should go to the guy too the very rare situation where i would change the matchup very rare.” Another host agreed, noting “it would have if it would have given this guy a win.”
We have been extraordinarily reluctant to order retroactive scoring adjustments. See Isaac v. Commissioner, 24-0858-1 (2024) (denying retroactive relief where manager failed to monitor injury news during 90-minute window before Monday Night Football). We have emphasized that managers bear responsibility for monitoring their rosters and that retroactive adjustments create moral hazard. See Mitch v. League Member, 24-0850-1 (2024) (holding that phone malfunction on Friday does not warrant retroactive lineup changes where manager failed to utilize alternative means of communication).
But this case presents none of those concerns. Petitioner did not fail to monitor his roster. Petitioner could not attend the draft due to insurmountable geographical and time zone barriers. Petitioner acted with extraordinary diligence by providing detailed written instructions identifying specific players by name. The failure was entirely the Commissioner’s—a failure not of negligence or oversight but of deliberate misconduct motivated by self-interest.
Where commissioner malfeasance directly causes a manager to lose a matchup he would have won absent the misconduct, we will order retroactive scoring adjustments. This is not about protecting managers from their own errors. This is about remedying competitive harm caused by fiduciary breach. If Egbuka’s Week 1 performance would have secured Petitioner a victory, those points should be credited to Petitioner’s Week 1 total. The Commissioner may not profit from his own wrongdoing by retaining both the player and the points generated during his unlawful possession.
V
We take this opportunity to establish best practices for commissioners managing auto-drafted teams. Where league members cannot attend drafts due to legitimate constraints—work obligations, travel, childbirth, military deployment, or here, residing across the Atlantic Ocean—commissioners who agree to execute draft instructions occupy positions of absolute trust. They must honor those instructions with scrupulous fidelity.
If a commissioner receives written instructions identifying specific players by name, those instructions are binding. The commissioner may not substitute his judgment for the absent manager’s preferences. If the requested player has already been selected, the commissioner should move to the next player on the list or, if no alternative is specified, contact the absent manager for guidance. What the commissioner may absolutely not do is ignore the specific instruction, select a different player, announce something misleading to the league, and then acquire the requested player for himself.
Where instructions are genuinely ambiguous, commissioners should err in favor of transparency. Announce the ambiguity to the league. Seek guidance from a neutral co-commissioner. Document the interpretation adopted. Never exploit ambiguity for personal competitive advantage. And if a commissioner has any doubt about whether his interpretation might benefit himself at the absent manager’s expense, the conflict of interest requires abstention or neutral adjudication.
Finally, we emphasize the human dimension of this case. As one host observed, Petitioner is “in Denmark and trying to be in your fantasy league.” He went to substantial effort to participate despite enormous logistical barriers. He prepared detailed written instructions. He trusted the Commissioner to honor those instructions. The Commissioner’s betrayal of that trust—his systematic acquisition of the players Petitioner specifically requested—represents a profound failure of the basic decency that fantasy football leagues depend upon.
Fantasy football exists because friends want to compete together. Leagues accommodate members who face obstacles to participation—whether military deployment, demanding work schedules, or living across an ocean—because those members’ participation enriches the competition and sustains the friendships that make fantasy football worthwhile. A commissioner who exploits those accommodations to steal assets from absent members undermines not merely competitive integrity but the social fabric that holds leagues together. That, he may not do.
* * *
During oral argument, one host asked rhetorically what came out that revealed the Commissioner’s scheme. The answer appears to be that Petitioner eventually reviewed his roster, noticed he had Waddle instead of Egbuka, and observed that the Commissioner had drafted Egbuka in round six. Perhaps Petitioner asked about it. Perhaps someone else noticed the discrepancy. However the revelation occurred, we are confident that once exposed, the Commissioner’s misconduct speaks for itself.
No reasonable person can defend this conduct. The Commissioner received written instructions. He ignored them. He selected different players. He acquired the specifically requested players for himself. He repeated this pattern multiple times. And when confronted, he maintained he did nothing wrong and refused to remedy the situation. This is not a close case requiring careful doctrinal analysis. This is, to use the technical legal term, scumbag behavior.
The Commissioner must immediately swap Waddle for Egbuka on the respective rosters. He must similarly swap Rice and Golden, restoring to Petitioner the players he specifically requested. If Egbuka’s Week 1 performance would have changed the outcome of Petitioner’s matchup—giving Petitioner a victory he was denied due to the Commissioner’s malfeasance—those points shall be credited to Petitioner and the Week 1 result shall be corrected accordingly.
We further recommend that the league seriously consider whether this Commissioner should retain his position. A commissioner who systematically exploits absent members, ignores explicit written instructions, and refuses to remedy his misconduct when confronted has demonstrated he lacks the basic trustworthiness the position requires. Leagues need commissioners who will fairly execute the ministerial duty of honoring draft instructions for absent members. This Commissioner has proven he cannot be trusted with that duty.
To Petitioner: we apologize that you traveled all the way from Denmark to Fantasy Court. But we are confident you will prevail. The Commissioner’s misconduct is black and white. The remedy is mandatory. And we hope your league—and every league confronting similar commissioner malfeasance—recognizes that fiduciary duties are not optional, that self-dealing is impermissible, and that commissioners who systematically betray the trust of absent members forfeit any claim to continued authority.
Player swaps ordered. Retroactive scoring adjustments permitted where Commissioner’s misconduct caused Week 1 loss.