UVA Law Chop League
v.
Austin Jones
79 U.Va. 9 (2026)
Koeppel, J., delivers the opinion of the Court, in which Berklich and Wu, C.J.J., and Boatright, Lozada, Lawson, Moore, and Vanger J.J. join.
Koeppel, J., delivers the opinion of the Court.
In the case at bar, the plaintiffs (hereinafter “UVA Law Chop League”), as a certified class, bring suit against Austin Jones (hereinafter “Commissioner Jones”), in his official capacity as commissioner of the “UVA Law Chop League.” The plaintiffs bring a panoply of state tort and contract law violations against Commissioner Jones.
Facts
This saga originated from a single trade.[1] From this trade on an early Saturday morning in October stems multiple alleged state tort and contract law violations.
On the morning of October 4th, 2026, Justice Samuel E. Koeppel and Jonathan Huffine completed a trade for Jauan Jennings in exchange for Blake Corum and $1,500 FAAB. On October 5th, encountering opposition to this unconscionable agreement, Mr. Huffine defended himself, claiming facetiously, “Sam gave me 10 dollars for that trade btw.” Due to the unequal nature of this initial exchange and the threat of embargo by the league, Mr. Huffine conveyed Mr. Koeppel $500 FAAB on October 6th. This conveyance by Mr. Huffine was vetoed by the defendant, Commissioner Jones.
Commissioner Jones subsequently fined both Koeppel, J. and Mr. Huffine $500 FAAB. Commissioner Jones released an AI-generated “Official Statement” announcing that the “UVA Law Chop Shop league office has determined that Jon and Sam engaged in an illegal trade this evening in violation of league rules and in direct threat to the integrity of [the] league.” The “Official Statement" threatened more severe penalties in the event of further violations.
In response to the “Official Statement,” Koeppel J., and Mr. Huffine released their own AI-generated “Official Announcement.” The “Official Announcement" read that “Sam and Jon do not accept Austin’s authority over them and will fight the $500 FAAB Fine in a court of law.” The announcement further stated that “Sam and Jon have retained the legal services of Wachtell, Lipton, Rosen & Katz to defend themselves against these spurious allegations.”
Koeppel J. and Mr. Huffine repeatedly appealed the $500 FAAB deduction; however, Commissioner Jones repeatedly enunciated the finality of his decision. James Bender, the Commissioner’s trusty sycophant, sought to ensure that Commissioner Jones would not reverse his decision by instilling fear of rebellion.
A direct appeal to the league by Koeppel J. resulted in an overwhelming vote that returning the $500 FAAB would be a sign of mercy rather than weakness from Commissioner Jones. Despite this authoritative vote and the exercise of popular sovereignty by the UVA Law Chop League, Commissioner Jones has failed to return Koeppel J.’s $500 FAAB.
The members of the UVA Law Chop League bring the following suit, as a certified class, alleging conversion of monies, breach of contract, and tortious interference.
Discussion
Governing Law:
The UVA Law Chop League is registered as a Delaware Corporation, but its principal place of business is Cancún in the state of Quintana Roo, Mexico, where Commissioner Jones will soon be spending time after his team is eliminated. However, the UVA Law Chop League intentionally directs much, if not all, of its commercial activity to Charlottesville, Virginia.
The Plaintiffs allege violations of Virginia state tort law. The defendant, Commissioner Jones, asserts that governing law is Mexican federal law, and thus the plaintiffs lack a cause of action.
Frankly, this Court does not have the patience or desire to engage in research about conflict of laws or choice of law doctrines, so this Court will half-hazardly engage in a discussion of jurisdiction and governing law.
In federal courts sitting in diversity, the choice-of-law rules of the forum state govern, not a uniform federal standard. See Klaxon Co. v. Stentor Elec. Mfg. Co., 313 U.S. 487 (1941) (holding that federal courts must apply the conflict-of-laws rules of the state in which they sit). The Court of Petty Appeals is not a federal court sitting in diversity, so we can disregard this kernel of civil procedure.
Instead, we devise our own choice-of-law doctrine. We hereby declare that all matters before this Court of Petty Appeals are governed by the law which fits the court’s narrative. Here, we resolve ourselves to apply Virginia state tort law because it functions as the easiest and most effective means of holding Commissioner Jones to account.
Conversion of Monies:
The Restatement (Second) of Torts § 222A provides that conversion is an intentional exercise of dominion or control over a chattel which so seriously interferes with the right of another to control it that the actor may justly be required to pay the other the full value of the chattel. See Restatement (Second) of Torts § 222A (1965).
Pursuant to Fax Connection, Inc. v. Chevy Chase Bank, F.S.B., 73 Va. Cir. 263, 264–265 (2007), conversion is the “taking of personal property by one person and the repudiation by that person of the owner’s rights, or the exercise of dominion over the property by that person in such a way as to be inconsistent with the rights of the owner. To assert a claim for conversion, a plaintiff must prove by a preponderance of the evidence (1) the ownership or right to possession of the property at the time of the conversion and (2) the wrongful exercise of dominion or control by the defendant over the plaintiff’s property, thus depriving the plaintiff of possession.”
Here, Commissioner Jones, absent authorization or expressed license by virtue of any governing by-laws, reduced the property of the plaintiffs, depriving them of possession and use of the property. All UVA Law Chop League players under the league rules possess $10,000 FAAB at the beginning of the season. That FAAB is expended by bidding on available players on the waiver wire. By reducing the plaintiffs’ FAAB, Commissioner Jones deprived them of possession and exercised control over the plaintiffs’ FAAB, over which they retained rightful ownership and possession.
The plaintiffs, thus, prevail on their claim of conversion against the defendant.
Breach of Contract:
Under Code of Virginia § 59.1-507.1, a breach of contract occurs if a party without legal excuse fails to perform an obligation in a timely manner, repudiates a contract, or exceeds a contractual use term, or otherwise is not in compliance with an obligation placed on it by this chapter or the agreement. A breach, whether or not material, entitles the aggrieved party to its remedies.
A breach of contract is material if the breach is a substantial failure to perform a term that is an essential element of the agreement; or the circumstances, including the language of the agreement, the reasonable expectations of the parties, the standards and practices of the business, trade, or industry, and the character of the breach, indicate that: the breach caused or is likely to cause substantial harm to the aggrieved party; or the breach substantially deprived or is likely substantially to deprive the aggrieved party of a significant benefit it reasonably expected under the contract. The cumulative effect of nonmaterial breaches may be material. See Code of Virginia § 59.1-507.1.
The plaintiffs request us to construe entrance into the UVA Law Chop League as an implied contract with Commissioner Jones, which he has breached. This Court is inclined to grant such a request for the sake of the bit.
This would be a contract for services, rather than goods. Thus, the common law governs. Based on the common law, we hold that the plaintiffs, by joining into the UVA Law Chop League, implicitly formed an implied contract with Commissioner Jones. This Court fills in any missing terms of this implied contract, relying on established trade usages within the local fantasy football industry. It is an established trade usage in this industry to prohibit unilateral reduction of FAAB by the league commissioner without due process. Commissioner Jones’ breach of this term constituted a material breach, and the plaintiffs are entitled to relief for breach of contract.
Tortious Interference:
To establish a prima facie claim of tortious interference with contract expectancy, prospective business relationship, or economic advantage, a plaintiff must prove at least four elements:
The existence of a contract expectancy, prospective business relationship or economic advantage;
Knowledge of the contract expectancy, prospective business relationship, or economic advantage by the defendant;
A reasonable certainty that, absent defendant's intentional misconduct, plaintiff would have continued in the relationship or realized the expectancy;
The defendant used improper means or methods to intentionally interfere with the contract expectancy, prospective business relationships, and economic advantage; and
Resultant damage to the plaintiff.
See Maximus, Inc. v. Lockheed Info. Mgmt. Sys. Co., 254 Va. 408 (1997).
By fining Koeppel J. and Mr. Huffine $500 FAAB, Commissioner Jones engaged in interference with the plaintiffs’ prospective economic advantage. Had Commissioner Jones not improperly fined the plaintiffs, there is a reasonable certainty that the plaintiffs would have realized the economic expectancy from their FAAB, namely bidding and acquiring additional players on the waiver wire. Commissioner Jones was aware of the existence of this prospective economic advantage, and nevertheless improperly and intentionally interfered with the prospective economic advantage that would have been derived from the $500 FAAB. In fact, interfering with this prospective economic advantage was the stated rationale for the fine, meant to act as a deterrent against supposed collusion and illegal trading.
Conclusion
This Court holds Commissioner Jones liable for conversion of monies, breach of contract, and tortious interference, and orders payment of $500 FAAB with interest to Koeppel, J., before the running of the next waiver wire.
[1] Admittedly a very poor trade by the justice authoring this opinion.