Petitioner’s league has a punishment. It has a draft where each member selected a bespoke consequence to befall whoever finishes last. What it does not have is a definition of “last place.”
Petitioner serves as commissioner of a ten-team work league. Six teams make playoffs; four do not. Now, with playoffs imminent, the league has discovered its omission. One faction says last place means the worst regular season record after Week 14—check the standings and assign the punishment. Another faction—Petitioner’s—says last place must be determined through a toilet bowl tournament among non-playoff teams during Weeks 15-17.
We hold that the toilet bowl format is correct. In fantasy leagues with punishment systems, last place is properly determined by tournament results, not by consulting standings and calling it a day. The alternative would tell four teams that their season is over with three weeks still to play. That, we cannot countenance.
I
The structure is straightforward. Ten teams. Six make playoffs: top four by record, next two by points scored. Four teams miss out. Before the season, each manager drafted a bespoke punishment—a unique consequence tailored to his particular circumstances and tolerances. The individualized nature heightens the stakes: whoever finishes last faces a punishment specifically designed for him.
But “last place” was never defined. And this is no mere semantic quibble. The two proposed interpretations produce radically different outcomes. Under the regular season approach, last place is fixed after Week 14—check the standings, identify the loser, impose the punishment. Done. Under the toilet bowl approach, the four non-playoff teams continue competing during Weeks 15-17, and only the loser of that bracket faces punishment.
We side decisively with the toilet bowl. It is not close.
II
We begin with first principles. Punishment systems exist to maintain competitive engagement throughout the season. As we explained in In re League Punishment Eligibility Standards, 24-0850-3 (2024), punishments “serve critical functions in maintaining league integrity and competitive incentives.” They create “year-round competitive pressure that prevents roster abandonment, trade deadline tanking, and the general malaise that can afflict teams eliminated from playoff contention.”
The choice between regular season standings and toilet bowl tournaments implicates these core functions directly. Regular season standings determination effectively ends the season for non-playoff teams after Week 14. Once the regular season concludes, the bottom four teams know their relative positions. The tenth-place team knows he has lost. The seventh-place team knows he is safe. Neither has any reason to set lineups, make waiver claims, or monitor player news during the playoff weeks. The season is over for them.
This outcome undermines everything punishment systems are designed to accomplish. As Petitioner put it: “Why would you tell people, ‘Yeah, after Week 14, don’t check the league anymore’?” You wouldn’t. Yet that is precisely what the regular season interpretation encourages.
The toilet bowl tournament solves this problem elegantly. All four non-playoff teams enter a bracket during Weeks 15-17. Seventh plays tenth. Eighth plays ninth. The winners advance to a championship for seventh place overall. The losers play a consolation game to determine who finishes last. Every game matters. Every team has concrete stakes. The ninth-place team that dominated the regular season’s bottom tier must now prove it in playoff competition. The tenth-place team has an opportunity to avoid last place through strong playoff performance. As Petitioner emphasized, “The whole point is you have to do the final few weeks.”
We established closely related principles in In re League Punishment Eligibility Standards, where we held that “consolation bracket games” must “matter” and that “participants compete meaningfully even after playoff hopes have ended.” We emphasized that punishment systems should ensure “no game becomes truly meaningless” and that “managers who might otherwise check out of the season” must have “powerful motivation to keep competing.” The toilet bowl tournament serves these exact purposes. It transforms Weeks 15-17 from dead time into meaningful competition with genuine stakes.
III
As Justice Horlbeck observed during oral argument, the toilet bowl is “way more dramatic” and “way more fun” than consulting final standings. More important for present purposes, it “incentivizes people at the bottom of the league to still try and focus on waivers.” Compare the incentive structures: Under regular season determination, the tenth-place team has lost—permanently, irrevocably, with three weeks remaining. Its manager has no reason to set a lineup. Under toilet bowl determination, that same manager must beat the seventh-place team in the quarterfinals or face punishment. One system breeds apathy. The other breeds drama.
We draw support from Chris v. League, 25-0705-1 (2025), where we held that punishment rules should achieve “entertainment value, roster engagement, and league bonding.” The toilet bowl advances all three. See also In re The 69 Points Rule, 25-0709-1 (2025) (holding that creative traditions “add an element of chaos, excitement, and humor” and “enhance league engagement”).
Opponents argue that regular season standings provide a more “fair” measure—fourteen weeks of performance rather than a three-week sample. But this misunderstands fantasy fairness. The toilet bowl does not ignore regular season performance; it builds upon it. Regular season record determines who makes playoffs and who enters the toilet bowl. Regular season roster construction determines who enters that bracket well-positioned to win. The toilet bowl simply adds one more layer: actual competition to determine the loser, rather than administrative fiat. We prefer competition.
IV
The record reveals that Petitioner’s league was “created for making content”—a podcast league where drama is not merely desirable but essential. This fact strengthens the case for toilet bowl determination. A content-driven league that tells four teams “your season ended in Week 14” has eliminated one quarter of its potential storylines for the final three weeks. Can the tenth-place team mount an improbable playoff run? Will the seventh-place favorite choke under pressure? These are storylines worth having. The toilet bowl creates them; regular season determination forecloses them.
But we emphasize that our holding extends beyond content-creation leagues. Whether a league exists for money, bragging rights, or podcast fodder, the toilet bowl better serves punishment systems’ purposes: engagement, roster management, and meaningful competition through the bitter end.
V
We turn finally to the commissioner’s authority to resolve this ambiguity. Petitioner, as commissioner, faces the unenviable task of determining last place without clear guidance from pre-existing rules. We hold that commissioners possess authority—indeed, obligation—to clarify ambiguous rules in ways that serve league interests. See In re Intoxicated Roster Transactions, 24-0854-2 (2024) (recognizing commissioner discretion to provide “emergency relief” or “punitive measures” as circumstances warrant). Petitioner’s proposed toilet bowl format serves clear league interests: engagement, competition, drama. The commissioner acts properly in adopting it.
We do note that ideally this ambiguity would have been resolved before the season began. Future commissioners should take note: when implementing punishment systems, specify how last place will be determined. Do not leave critical terms undefined. But the failure to clarify ex ante does not doom the league to chaos. Commissioners may and should resolve such questions when they arise. Here, those principles overwhelmingly favor the toilet bowl.
* * *
Petitioner’s instinct was correct. The toilet bowl format has proven itself the superior method for determining last place. It keeps everyone engaged. It creates drama. It ensures that no team’s season ends until the season actually ends. We now establish it as the governing standard: in fantasy leagues with punishment systems, last place is determined by toilet bowl tournament results among non-playoff teams—not by consulting Week 14 standings and calling it a day.
Last place shall be determined by toilet bowl tournament. The commissioner shall implement appropriate bracket competition among non-playoff teams during Weeks 15-17.