Petitioner Tim, a fantasy manager from Ireland, found himself mathematically eliminated from playoff contention on the Sunday of Week 14. His season was over. His championship aspirations had expired. But one slender thread of agency remained: his starting quarterback, Jalen Hurts, was scheduled to play Monday Night Football. By benching Hurts, Petitioner could deliberately lose his matchup and thereby eliminate a league rival from playoff contention—a rival who had joined the league four years prior, won three of those four championships, and personally eliminated Petitioner from contention each season.
Petitioner sought an advisory opinion from this Court on the permissibility of this maneuver prior to kickoff. We hold that such conduct is impermissible: a manager may not deliberately leave a roster position empty to throw a matchup and manipulate playoff outcomes. However, we dismiss the petition as moot, for in a twist of cosmic justice that even this Court could not have scripted, Jalen Hurts proceeded to score approximately 0.4 fantasy points. The rival was eliminated regardless of Petitioner’s decision. The universe delivered what Petitioner sought to engineer through roster manipulation.
I
We begin with the foundational principle articulated in Zach v. Andy, 24-0810-1 (2024): “managers must field complete rosters with players in all required positions.” That case established that a manager who has clinched a playoff bye may intentionally field a suboptimal lineup to influence playoff seeding and potentially eliminate a league rival—”provided the manager fields a complete roster with players in all required positions rather than leaving positions empty.”
The distinction is critical. Zach v. Andy drew a bright line between strategic lineup manipulation and outright forfeiture. A manager may start his worst running back over his best. He may bench his stud wide receivers in favor of end-of-bench depth pieces. He may field a quarterback on a short week facing a dominant defense. These decisions remain “legitimate roster choices operating within the league’s competitive structure.” But leaving positions empty “constitutes impermissible forfeiture rather than permissible strategy.”
This case falls on the impermissible side of that line. Petitioner did not have an alternative quarterback on his roster. His question to the Court was whether he could simply bench Hurts and start no one in his place. That, he may not do.
II
We have previously endorsed various forms of strategic roster manipulation undertaken in pursuit of competitive advantage or even naked spite. In John v. Brother, 21-1219-1 (2021), we held that a manager could deliberately bench Aaron Jones out of “pure Australian Spartan spite” to sabotage his brother’s playoff chances after the brother announced he was relocating to Australia. We celebrated such conduct as “the kind of petty, emotional, gloriously spiteful conduct that makes fantasy football leagues memorable decades later.”
But the manager in John v. Brother benched one player while starting others. He fielded a complete roster—just a deliberately suboptimal one. The same distinction appeared in Billy v. Commissioner, 20-1340-1 (2020), where we permitted strategic tanking to manipulate playoff seeding. And in Kristen v. Husband, 21-1223-1 (2021), we allowed a manager to leave bye-week players in his lineup against his spouse because doing so “serve[d] his roster management interests by avoiding disadvantageous player drops.”
In each case, the manager made a choice among available options—starting suboptimal players, preserving roster depth, expressing familial displeasure through lineup construction. What none of those cases involved was a manager who had no choice at all except to vacate a position entirely.
The difference matters. A manager who fields a suboptimal lineup remains within the competitive system. He is managing his roster, albeit toward ends that may not maximize his point total. A manager who leaves positions empty has abandoned roster management entirely. He is not playing fantasy football that week—he is refusing to play at all.
III
We pause to address Petitioner’s implicit appeal to what one might call the “Rule of Cool”—the notion that some conduct is sufficiently funny, dramatic, or memorable that it should be permitted regardless of its formal legality. We acknowledge the appeal. The scenario Petitioner describes has undeniable dramatic flair: three years of playoff heartbreak at the hands of a dominant rival, a final act of defiance from a mathematically eliminated team, a last-second decision to sacrifice personal integrity for competitive revenge.
But the Rule of Cool cannot override the fundamental requirement of competitive participation. As we observed in In re The Vase Trophy Controversy, 25-0717-1 (2025), competitors who decline to compete forfeit the privileges of competition. There, two championship finalists agreed to bench their entire rosters to force a 0-0 tie and split the prize money. We held they forfeited the right to have their names engraved on the league trophy: “They got the money. They may not also claim the glory.” The principle applies here with equal force. If Petitioner declines to field a quarterback—if he refuses to compete in his matchup—then he has stepped outside the competitive system that generates the drama he seeks to create.
There is also a practical concern. If we permitted managers to leave positions deliberately empty to manipulate playoff outcomes, we would create a chaotic endgame scenario in the final weeks of every fantasy season. Eliminated teams could auction their losses to the highest bidder among playoff contenders. Managers facing rivals they dislike could tank their matchups without even the pretense of fielding a roster. The entire Week 14 landscape would become an exercise in strategic forfeiture rather than competitive play.
We will not open that door. The competitive structure of fantasy football depends on the assumption that each manager, each week, will field a complete roster and allow player performance to determine outcomes. Managers who have secured favorable positioning may choose to field suboptimal lineups—that is their prerogative under Zach v. Andy. But managers may not simply refuse to participate by leaving positions vacant. That is where gamesmanship ends and sabotage begins.
IV
We acknowledge a hypothetical distinction raised during oral argument. If Petitioner had possessed a second quarterback on his roster—any quarterback at all—he might have started that player over Hurts regardless of relative merit. A manager who starts Trey Lance over Jalen Hurts has made a roster decision, however questionable. A manager who starts no one has made no roster decision at all.
This distinction may seem formalistic, but it reflects a genuine difference in competitive posture. The manager who starts Lance is declaring: “I believe this player gives me the best chance to accomplish my competitive objectives this week, even if those objectives include strategic losing.” The manager who starts no one is declaring: “I decline to participate in fantasy football this week.” The former remains within the competitive system. The latter has abandoned it.
Petitioner did not have a second quarterback. He could not have prepared in advance by picking up an alternative, because the question reached him only after the Sunday games had concluded. His only option was to bench Hurts and field an empty position. Under our precedents, that option was unavailable to him.
* * *
We conclude by noting the extraordinary mootness that overtook this proceeding. Petitioner sought guidance on whether benching Jalen Hurts would constitute permissible gamesmanship. While the Court deliberated, Hurts took the field against the Carolina Panthers—and proceeded to engineer one of the more spectacular quarterback disasters in recent memory. A fumble. An interception. Minimal yardage. Approximately 0.4 fantasy points in total.
Petitioner’s rival was eliminated from playoff contention anyway. The cosmic irony is too rich to ignore: Petitioner agonized over whether to bench his quarterback as an act of sabotage, only to watch that quarterback sabotage himself far more effectively than any roster manipulation could have achieved. As several league members who wrote to this Court observed, Hurts accomplished through incompetence what Petitioner sought to accomplish through strategy.
There is perhaps a lesson here about the limits of managerial agency in fantasy football. We spend considerable energy optimizing our rosters, agonizing over lineup decisions, and seeking competitive advantages through information and strategy. But sometimes a quarterback throws a pick at the wrong moment, or fumbles at the goal line, or simply fails to produce in ways no projection could have anticipated. Fantasy football, like life itself, contains irreducible elements of chance that no amount of roster manipulation can eliminate.
Petitioner’s petition sought to control outcomes through forfeiture. The universe controlled outcomes through Jalen Hurts’s performance. We find the universe’s method preferable. Let managers compete. Let players perform. Let the chips fall where they may. And when those chips fall in spectacular fashion—when a starting quarterback scores fewer than half a fantasy point in a crucial Monday Night Football game—let us appreciate the cosmic comedy that no deliberate sabotage could have scripted better.
For the foregoing reasons, we hold that Petitioner’s proposed conduct would have been impermissible had it been executed. But we dismiss the petition as moot, as the challenged conduct was rendered academic by events beyond Petitioner’s control.
Petition dismissed as moot.