Pat flew from Philadelphia to Los Angeles to attend the Eagles-Rams game. Before kickoff, he met Steve—a fellow member of their eighteen-year-old dynasty league—for a round of golf. On the course, they wagered their first-round picks in the 2026 rookie draft. Steve won. Pat, demonstrating the kind of judgment that explains his fantasy football record, proposed double-or-nothing on the 18th hole, staking his second-round pick in 2027. Pat lost again. As a consequence, Pat now owes Steve his first-round pick in 2026 and his second-round pick in 2027—compensation comparable, Commissioner Dan notes, to the Quinnen Williams trade.
The Commissioner seeks guidance on whether to honor and process this transfer of picks. We hold that he must. Where two consenting adult league members wager draft picks on their own personal competition, and where the consideration remains entirely within the fantasy football system, principles of managerial autonomy govern. Pat made his bet and lost. That, as they say, is golf.
I
We begin with our precedent in Steve v. League, 21-1227-2 (2021), which directly addressed the wagering of dynasty draft picks on external events. In that case, an admittedly intoxicated league member wagered his first-round pick on the outcome of the World Series—specifically, whether the Atlanta Braves would prevail. We held that “league members may not unilaterally wager dynasty draft picks on events wholly external to fantasy football—specifically, Major League Baseball playoff outcomes—without obtaining prior league-wide approval.”
The Commissioner—and Chief Justice Heifetz—would read Steve v. League as controlling here. After all, golf is not fantasy football. A wager on whether Pat can escape a bunker on the 18th hole has nothing to do with player evaluation, roster construction, or the skills that dynasty leagues exist to reward. If MLB playoffs constitute an impermissible external event, why should a Saturday golf match receive different treatment?
We acknowledge the force of this argument. But Steve v. League does not control this case, and careful attention to its reasoning reveals why.
II
In Steve v. League, we identified two distinct concerns with external wagering of draft picks. First, we observed that such wagers “introduce into the league’s closed competitive system an external source of volatility completely unrelated to the skills and knowledge that fantasy football rewards.” The MLB playoff wager had “nothing to do with fantasy football” because it reflected the wagering member’s “assessment of baseball rather than football.”
Second, we emphasized the risk of destabilization by disengaged or bored members: “What happens when a bored manager in June—months before the fantasy season begins—starts gambling next year’s draft picks on the NBA Finals, the Stanley Cup playoffs, or political election outcomes?” We warned that permitting such wagers would transform “dynasty draft picks from carefully managed assets used to construct football rosters into gambling chips wagered on whatever external events catch managers’ fancy.”
Both concerns are substantially diminished here. This is not a case where a bored or intoxicated manager wagered league assets on events involving third parties in unrelated sports. Pat and Steve wagered picks on their own competition—a head-to-head golf match between the two parties to the transaction. The wager arose organically from their social interaction as league mates and friends. And critically, the consideration remained entirely within the fantasy football system: picks for picks. No cars were exchanged. No external monetary consideration changed hands. The loser forfeited draft capital; the winner gained it. The league’s zero-sum draft economy remains intact.
This distinction matters. In Steve v. League, we distinguished between “permissible risk-taking within the fantasy football system and impermissible wagering of league resources on external events.” The MLB playoff wager fell in the latter category because the manager was gambling league resources on events in which he had no personal participation. He was merely a spectator, betting on third parties playing baseball.
Pat and Steve were not spectators. They were competitors, wagering on their own athletic contest. This is more analogous to the poker hypothetical we raised in Steve v. League—where a manager “tilting” puts “the deed to your house down” and starts “giving away dynasty first rounders”—than to passive gambling on external sporting events. When league mates compete directly against each other and stake fantasy assets on the outcome, the competitive nature of the wager connects it to the competitive nature of the league itself.
III
We are mindful that reasonable minds may differ on where to draw this line. Chief Justice Heifetz, in his concurrence, argues that the principle of Steve v. League should extend to any wager on non-football events, regardless of whether the parties themselves are competing. He would require league approval before any such wager may proceed.
We respectfully disagree. Fantasy football leagues are social institutions, and the bonds between league mates extend beyond Sunday afternoons. When Pat flew across the country to attend a football game and meet up with Steve for golf, he was engaging in precisely the kind of camaraderie that makes dynasty leagues endure for eighteen years. That their friendly competition spilled over into wagering draft picks reflects—perhaps excessively—the spirit of competition that animates the league itself.
Moreover, the principle of managerial autonomy counsels in favor of allowing the transfer. As we held in James v. League, 24-0846-2 (2024), “each league member possesses the sovereign authority to manage their roster as they see fit. This includes the freedom to make trades that others consider unwise.” We emphasized that “it is not your job to manage other people’s teams” and that the remedy for poor judgment is “not to veto the transaction but to exploit their poor judgment to your own advantage.”
Pat exercised poor judgment. Spectacularly poor judgment. Having lost his first-round pick on the golf match, the rational response would have been to shake hands, compliment Steve’s short game, and move on to watching the Eagles. Instead, Pat proposed double-or-nothing on the 18th hole, staking additional draft capital on a contest he had already demonstrated he could not win. This is the kind of decision-making that earns managers the last pick in snake drafts. But it is his decision to make.
As Justice Horlbeck observed during deliberations: “If these two guys made a bet about giving up your first round pick, whoever loses, and one guy lost—what’s the problem there?” The answer is that there is no problem, provided the consideration remains within the fantasy system and both parties entered the wager freely. Pat was not coerced. He was not deceived. He simply lost at golf and then—inexplicably—decided to lose more at golf.
IV
We address the distinction raised during oral argument regarding external consideration. Justice Kelly referenced a prior incident where a league mate “traded a pick for a car in real life”—specifically, “some running back” for an automobile. We agree with the Court’s assessment that such transactions present different concerns.
When fantasy football assets are exchanged for external consideration—money, vehicles, services, or other real-world value—the league’s closed competitive system is compromised. As we explained in Commissioner v. Danny, 21-1234-1 (2021), offering “material compensation outside the fantasy football system—specifically, beer—to induce waiver wire moves” constitutes collusion because it introduces “external inducements” that “manipulate league outcomes.” A manager who trades a first-round pick for a car is not making a football decision; he is conducting a commercial transaction using league assets as currency.
The present case does not implicate these concerns. Pat did not receive anything from Steve other than the opportunity to compete—and the opportunity to lose. The consideration on both sides consisted exclusively of draft picks. No external value entered or left the system. As Justice Horlbeck emphasized: “If it’s pick for pick, I’m like, what?” Precisely. Pick for pick remains within the fantasy domain, even if the mechanism for determining which party receives the picks occurs on a golf course rather than in a trade negotiation.
We acknowledge that Chief Justice Heifetz would draw the line differently. He posits that if this same scenario occurred in a redraft league—if two managers showed up to the draft and announced that one had won two additional first-round picks in a golf match the previous day—the league would “freak out.” This is probably true. And it suggests that leagues possess legitimate interests in regulating such arrangements.
But that interest is best protected through prospective rulemaking, not retroactive voiding of completed transactions. Commissioner Dan’s league has no rule prohibiting the wagering of draft picks on golf matches. Pat and Steve violated no existing norm. They simply did something unusual—something the league had never contemplated and therefore never prohibited. The remedy is not to punish them retroactively but to establish clear rules going forward.
V
We turn finally to the question of remedy. Chief Justice Heifetz suggests that even if the transfer should proceed, some punishment is warranted—perhaps deleting the first-round pick entirely rather than transferring it to Steve, as a sanction for Pat’s recklessness. This would leave Steve with only the 2027 second-round pick while Pat forfeits both picks to the void.
We decline to adopt this approach. Where league rules do not prohibit conduct, and where both parties entered the arrangement voluntarily, imposing sanctions serves no legitimate purpose. Pat was not cheating. Steve was not colluding. They were competing, wagering, and one of them lost. The consequence of losing a wager is that your opponent wins—not that the stakes disappear into the ether.
Fantasy football, like golf, rewards winners and punishes losers. Steve won. He is entitled to his winnings. Pat lost. He must pay his debts. This is how wagers work. This is how competition works. And this is how dynasty leagues should work when two consenting adults stake their picks on a personal contest.
* * *
We hold that Commissioner Dan must process the transfer of picks as agreed by the parties. Steve receives Pat’s first-round pick in 2026 and second-round pick in 2027. Pat receives the valuable lesson that pressing bets on the 18th hole rarely improves one’s position.
We note, as Chief Justice Heifetz emphasizes in his concurrence, that this holding does not prevent the league from adopting rules governing such arrangements going forward. If the league wishes to prohibit wagering of draft picks on golf matches, poker games, or other extracurricular competitions, it may do so through the ordinary rulemaking process. What it may not do is void a transaction that violated no existing rule, harmed no one except the voluntary loser, and kept all consideration within the fantasy football system.
Pat made his bed on the golf course. He must now lie in it—without his first-round pick in 2026 or his second-round pick in 2027.
Transfer of picks ordered.
Chief Justice Heifetz, concurring in the judgment.
I concur in the judgment because the league has no rule prohibiting this conduct and retroactive punishment seems inequitable. But I write separately to express my concern that the majority’s reasoning extends too far.
The principle of Steve v. League, 21-1227-2 (2021), was that league members should not unilaterally wager draft picks on events “wholly external to fantasy football.” The majority distinguishes that case on the ground that Pat and Steve were competing against each other rather than spectating on third-party events. I find this distinction unpersuasive. Whether Pat loses his first-round pick because the Braves won the World Series or because Steve sank a putt on the 18th hole, the outcome has nothing to do with fantasy football.
The majority emphasizes that consideration remained “pick for pick” within the system. But Steve v. League was also pick for pick—first-round pick versus seventh-round pick—and we voided that arrangement. The problem in Steve v. League was not external consideration; it was external determination. The outcome of the wager depended on events unrelated to fantasy football skill or judgment. The same is true here.
I would hold that leagues must vote on whether to permit such arrangements. Whatever they decide becomes policy going forward. If Commissioner Dan’s league wishes to embrace golf-course gambling as part of its competitive culture, so be it. If they wish to prohibit it, that too is their prerogative. But the decision should be made collectively, not imposed by two managers who decided over nine holes that draft picks make excellent wager stakes.
Because the league had no rule prohibiting this conduct, and because Pat entered the wager voluntarily, I concur in allowing the transfer to proceed. But I would encourage Commissioner Dan to put this question to a league vote before next season’s draft. If the guy was dumb enough to bet his picks, perhaps he should not be bailed out—but neither should leagues be forced to accept ad hoc gambling arrangements they never contemplated.