Petitioner Dakota negotiated a trade with a league mate: Dakota would send Emeka Egbuka and receive Trey McBride in return. Both parties agreed to the terms. Within minutes of the trade being proposed, the league membership voted to veto the transaction. The stated justification: Dakota’s team was “already good enough” and league members did not want Dakota to improve further and potentially win the league. No allegations of collusion, intoxication, apathy, or other traditional bases for veto were raised.
We hold that the veto is invalid and the trade must be allowed to proceed. League members may not transform themselves into a fantasy football homeowners’ association empowered to veto transactions simply because they dislike the competitive implications. Trade vetoes exist to prevent collusion and bad faith dealing, not to enforce competitive balance or prevent successful teams from getting better.
I
We begin by reaffirming a foundational principle of fantasy football: managerial autonomy. Each league member possesses sovereign authority to manage their roster as they see fit. This includes the freedom to execute trades that improve one’s team, even where—perhaps especially where—one’s team is already competitive. To hold otherwise would be to say that success breeds restriction, that managers who draft well or trade shrewdly must be handicapped by their league mates’ vetoes lest they become too dominant.
That is not fantasy football. That is a participation trophy regime where leagues actively prevent excellence to ensure mediocre teams remain competitive. We reject that framework categorically.
The principle of managerial autonomy is not new to our jurisprudence. In James v. League, 24-0846-2 (2024), we held that “managerial autonomy prevails over paternalistic intervention in trade decisions” and that “trade vetoes exist solely to prevent collusion, concealed terms, or bad faith dealing such as league abandonment—not to protect managers from their own poor judgment or to enforce third-party assessments of fair value.” We emphasized that “where both parties voluntarily agree to a trade serving their perceived competitive interests, the transaction must stand even if it appears lopsided to outside observers.”
The same logic applies with even greater force here. In James, the objecting party at least argued the trade was substantively unfair—that one side was giving up too much value. Here, the league makes no pretense that the trade is unfair between the two parties. Both Dakota and the counterparty negotiated in good faith and agreed on terms each believed improved their respective rosters. The league’s complaint is not that the trade is lopsided, but that it makes Dakota’s already-strong team even stronger. In other words, the veto is not about fairness between the trading parties—it is about preventing Dakota from winning the league.
That rationale is impermissible. If leagues could veto trades to prevent strong teams from improving, every contender would face a perpetual embargo. The second-place team could not trade. The third-place team could not trade. Any transaction that might alter playoff positioning would be subject to collective override. Fantasy football would devolve from a competition rewarding shrewd roster construction into a managed economy where league committees determine which teams may improve and which must be held back in the name of “competitive balance.”
As we observed during oral argument: it is not your job to manage other people’s teams. If Dakota’s team is already strong and he successfully negotiates a trade to make it stronger, that is his prerogative. Your remedy is not to veto his transaction but to improve your own roster through waivers, trades with other league members, or better lineup decisions. You do not get to vote on whether Dakota’s fence is painted the right color.
II
Trade veto authority, properly understood, is narrow and targeted. Vetoes exist to prevent two specific categories of misconduct: (1) collusion, and (2) bad faith dealing or league abandonment. See James v. League, 24-0846-2 (2024).
Collusion occurs when managers coordinate to benefit one another through transactions that violate principles of good faith dealing. See In re Retaliatory Trading Scheme, 20-1345-1 (2020) (establishing good faith standard). This includes secret side agreements, see League v. Snake, 20-1331-1 (2020) (voiding trade with concealed draft pick consideration), and transactions where one party acts solely to benefit another in exchange for external consideration. See Dave v. Joe, 21-1223-2 (2021) (holding that managers may not exchange roster players for agreements to bench starting lineups).
Bad faith dealing occurs when a league member stops participating meaningfully in the league and dumps valuable players to friends or favored contenders. The classic example: a manager stops checking his team after Week 3, then in Week 10 suddenly trades all his valuable players to the friend who recruited him into the league. That transaction is voidable not because it is lopsided, but because the manager has abandoned the league and is funneling assets to a specific competitor rather than competing in good faith.
Neither category is present here. Dakota and his trading partner both remain engaged with the league. Both negotiated terms each believed improved their respective rosters. Both acted in pursuit of their own competitive interests. The trade involved no secret side deals, no external consideration, and no evidence that either party has abandoned the league or stopped competing. This is a standard trade between consenting managers who reached mutually acceptable terms.
The league’s veto thus falls outside any legitimate basis for trade intervention. The complaint is not collusion or bad faith—it is competitive jealousy dressed up as concern for league balance. As the league members themselves admitted, they “did not want Dakota to win because the team’s already good enough.” That is textbook improper veto rationale.
III
We pause to address the real-world analogy that exposes the absurdity of the league’s position. In actual professional sports—where billions of dollars are at stake rather than fantasy bragging rights—trades are almost never vetoed. The NFL does not ask the other 31 teams whether they think a trade between two franchises is fair before allowing it to proceed. The NBA does not permit league-wide voting to block transactions that might make strong teams stronger.
Indeed, in the entire modern history of major professional sports, there has been one—one—trade veto: the proposed Chris Paul trade to the Lakers in 2011, which occurred only because the NBA literally owned the New Orleans Hornets at the time and would have been trading with itself. That unique conflict of interest aside, professional leagues do not interfere with trades between franchises.
Consider the absurdity if they did. When the Philadelphia Eagles traded for A.J. Brown, the other NFC East teams did not get to vote on whether the transaction should proceed. Jerry Jones and the New York Giants did not convene an emergency session to block the trade on grounds that “the Eagles are already good enough and we don’t want them getting A.J. Brown.” The trade happened because two teams—the Eagles and the Titans—agreed on terms each believed served their respective interests.
If professional leagues with enormous competitive and financial stakes do not veto trades to preserve competitive balance, fantasy football leagues with $50 buy-ins certainly should not. The principle is identical: teams make their own decisions, live with the consequences, and compete within the rules. Collective second-guessing of individual roster decisions is antithetical to competitive sports.
IV
The league’s conduct here represents what we might call the “fantasy football HOA problem”—league members acting as a homeowners’ association policing transactions that offend their collective sensibilities. Your fence is the wrong color. Your grass is too tall. Your team is too good and you may not improve it further.
This mindset is corrosive to fantasy football competition. It transforms leagues from meritocratic competitions rewarding shrewd evaluation into managed economies where committees decide which teams may trade and which must be handicapped. It punishes success. It rewards mediocrity. And it fundamentally misunderstands what trade vetoes exist to accomplish.
Vetoes are not about predicting the future or enforcing your assessment of fair value. Indeed, the entire popularity of football stems in part from its spectacular unpredictability. Every season, experts’ predictions prove wildly wrong. Consensus rankings miss badly on player performance. Injury luck determines championships as much as roster construction skill. The notion that league members are qualified to predict whether Emeka Egbuka or Trey McBride will finish with more fantasy points—and should veto trades based on those predictions—is hubris masquerading as oversight.
Moreover, we receive veto cases every year where trades that appeared lopsided at the time turned out to be brilliant for the party everyone mocked. The manager who “overpaid” for an injured player who returned to dominance. The manager who “gave away” a star who immediately got hurt. Predicting player performance is extraordinarily difficult even for experts who do this professionally. League members scrolling Twitter for consensus rankings are not qualified to override mutually agreed-upon trades based on their amateur valuations.
As we observed during oral argument, this is America. You have the right to be stupid. People get to make bad decisions. It is part of freedom. If Dakota’s trading partner made what you consider a poor evaluation of Trey McBride’s value, that is his prerogative and his problem. Your remedy is to exploit his poor judgment by offering your own trades, not to protect him from himself through collective veto.
V
We address briefly the league’s voting mechanism, which appears to permit league-wide vetoes of proposed trades. Such systems are disfavored. As we emphasized during oral argument, there should not be votes for vetoing trades. Commissioners should act and rule with an iron fist, intervening only when clear evidence of collusion or bad faith dealing exists.
League-wide voting systems create precisely the problem we confront here: they invite other league members to manage rosters that are not theirs. They transform veto authority from a narrow tool preventing collusion into a broad weapon whereby coalitions of jealous managers can block any transaction they dislike. They encourage the fantasy football HOA problem by giving every league member a say in whether someone else’s fence is painted the right color.
The better approach is to vest veto authority exclusively in commissioners, who should exercise that power sparingly and only when clear evidence of improper dealing exists. Commissioners may review trades to ensure both parties understand the terms and are acting in good faith. See James v. League, 24-0846-2 (2024) (noting that commissioners may “spend a minute with the person [they] think is getting swindled” to confirm understanding, but should approve the trade if both parties confirm their intent). But once both parties confirm they understand the trade and want to proceed, the commissioner should approve it regardless of whether the commissioner or other league members consider it fair.
Here, even if we assume the league’s voting system is permissible, the veto fails because the stated rationale—preventing Dakota’s already-strong team from improving—is categorically improper. Commissioners reviewing this transaction should approve it immediately. League members have no legitimate basis to override.
* * *
Dakota negotiated a trade in good faith with a willing counterparty. The league vetoed it not because of collusion or bad faith dealing, but because Dakota’s team is “already good enough” and league members fear he might win. That rationale offends the foundational principles of fantasy football competition.
Managerial autonomy means managers may improve their teams through mutually agreed-upon trades regardless of how strong those teams already are. Success does not breed restriction. If Dakota is dominating through superior roster construction and shrewd trades, his league mates’ remedy is to compete harder and try to beat him—not to veto his transactions to handicap his advantage.
We hold that vetoes predicated on “competitive balance” or assertions that one party’s team is “already good enough” are categorically improper. Trade vetoes exist solely to prevent collusion and bad faith dealing. Where two engaged managers negotiate in good faith and agree on terms, their transaction must proceed. Let people manage their own teams. Stop managing other people’s teams. That is fantasy football.
Jealousy is not a basis for veto authority. It never has been. It never will be.
Trade veto overturned. Trade shall proceed as agreed.