LIV Golf v. PGA Tour and the Future of Professional Golf

The staid world of professional golf was upended in 2022 with the entry of LIV Golf, a circuit of invitational tournaments featuring both individual and team play. Financed by the vast resources of Saudi Arabia’s Public Investment Fund (“PIF”), LIV Golf recruited some of the world’s top golfers, including Phil Mickelson and Dustin Johnson, by paying each signing bonuses, appearance fees, and tournament purses amounting to tens of millions of dollars.¹ The breakaway circuit positioned itself as an alternative to the PGA Tour, the top level of professional golf. Given that LIV Golf stages its competitions on the same weekends and often on the same continent as PGA Tour events, the Tour invoked its contractual rights and regulations to suspend golfers who took the money and played for LIV.² Eleven of those golfers responded with an antitrust lawsuit against the PGA Tour, filed in the Northern District of California.³ That lawsuit has expanded to include other parties and claims, and is now progressing through pretrial discovery.

For more information on this issue from a UK law perspective, please see this LawInSport article.⁴

This article describes the PGA Tour’s financial and regulatory model and the broader professional golf ecosystem, as understanding this context is essential to evaluating the pending antitrust lawsuit. It then examines the antitrust claims that seek to dismantle the Tour’s model, details the progress of that lawsuit and additional claims and parties that have since been added, and explains how LIV Golf’s entry has already transformed the golf ecosystem.

Article outline:

The PGA Tour’s Financial and Regulatory Model
How Does LIV Golf differ from the PGA Tour
Other Participants in the Professional Golf Ecosystem
The Antitrust Lawsuit Early Stages
PGA Tour Goes on the Offensive
Pretrial Discovery and Adding LIV’s Saudi Backers to the Lawsuit
The Future of the Lawsuit and Professional Golf

The PGA Tour’s Financial and Regulatory Model

The PGA Tour, Inc. is organized as a non-profit trade association. Its membership comprises professional golfers who have aggregated their media and publicity rights to jointly negotiate for television exposure and corporate sponsorship of their tournaments. ⁵ The value of those agreements and the revenue that flows from them depends on the individual golfers’ collective guarantee of:

representative fields at tournaments throughout the Tour’s season, and
exclusivity with regards to competing golf events.

The value of TV and sponsorship deals resides in aggregating member golfers’ rights and assigning them to the Tour to sell, with the members agreeing to participate in a minimum of 15 Tour events over the season, and not participate in conflicting golf events and programming. CBS Sports would pay a lot less for televising a tournament if PGA Tour members were free to play in another tournament being held at the same time, or could individually sell their live or archival broadcast rights. The member golfers reap the benefit of bundling their rights through richer purses.

Individual golfers are independent contractors, not employees of the trade association dubbed the PGA Tour. Many individual professional sports circuits are organized this way, largely at the behest of the athletes because it provides them with autonomy and control over their schedules, business opportunities, and finances. It is the PGA Tour’s Commissioner, executives, and staff who are employees of the trade association, which serves as a flow-through entity for compensating the professional golfers who play in tournaments each year, funding various benefit plans, and supporting golf-related charities. Each year the composition of the Tour’s membership changes as golfers qualify for their Tour cards based largely on past performance. Note that the PGA Tour is entirely distinct from the PGA of America which is an organization for club professionals, i.e., teaching pros.

Over the course of a PGA Tour season, member golfers are eligible for three or more “conflicting event” releases to play in non-Tour tournaments outside North America. ⁶ The Commissioner retains discretion to condition those releases on commitments to play in specific Tour events in the future, or to deny releases if it would cause the Tour to violate a contractual commitment or would harm the Tour and its sponsors. Releases were denied to every player seeking to play in a LIV Golf event. Member golfers may resign the Tour at any time to play on a competing tour, including LIV, or to start their own circuit of golf events. And some Tour members who defected to LIV did exactly that.⁷

How Does LIV Golf Differ from the PGA Tour

The PGA Tour stages a golf tournament almost every weekend of the year. A typical Tour event offers a field of between 128 and 156 golfers who compete against each other over four rounds of stroke play (72 holes of golf) to post the lowest score. There is a “cut” after the first two rounds, after which about half the field continues to compete and remains eligible for prize money. In the past, players who are cut have gone home empty-handed, although that has changed to some degree since LIV Golf’s emergence. PGA Tour membership requires playing at least 15 tournaments each year to honor commitments made in the sponsorship and media rights deals that fund the purses.

By contrast, LIV Golf offers shorter tournaments with smaller fields — three rounds of golf instead of four (54 holes), and only 48 players competing in concurrent individual and team play events. Thus, the name LIV (rhymes with “give”), which is the Roman numeral for 54. There is no “cut” in LIV golf events. Every golfer plays all three rounds and is guaranteed prize money that far exceeds potential earnings on the PGA Tour. After the 2022 inaugural season featuring 8 events, LIV Golf plans to offer 14 events in 2023. Its 48 golfers must commit to playing in every event and agree to exclusivity provisions analogous to those in the PGA Tour regulations. Unlike the PGA Tour, LIV is not dependent on TV and sponsorship deals to fund its events, although it recently entered into deals to start generating such revenue.⁸[1] To date, LIV’s exorbitant signing bonuses and prize money have been funded almost entirely by the Saudi PIF.

Other Participants In the Professional Golf Ecosystem

Another key participant in the professional golf ecosystem is the Official World Golf Rankings (“OWGR”), which ranks golfers based on relative performance at eligible tournaments, typically only those that offer the classic four rounds of stroke play. PGA Tour events offer the most ranking points as they attract the most skilled golfers. Golfers will not earn ranking points from LIV events unless an exception is made—its application is pending. That will eventually catch up to LIV golfers in future years when they contend to play in the independent “major” tournaments that are not part of any tour: the Masters, U.S. Open, Open Championship (British), and PGA of America Championship. The majors select their fields in large part based on OWGR ranking points, as well as prior tournament victories and qualifying events.

Other professional golf tours operate throughout the globe, most elite among them the DP World Tour (a.k.a. the European Tour), which has entered a strategic partnership with the PGA Tour allowing their members to play in either (if qualified). The DP World Tour also banned its members who played for LIV from its events and fined them each £100,000 for violating its tour regulations. Pursuant to those regulations, the LIV golfers challenged these disciplinary sanctions in a neutral private arbitration, which issued a final, unappealable decision upholding the ban and fines.⁹ The PGA Tour also operates regional and developmental tours including the Tour Latinoamerica and the Korn Ferry Tour. Tours not affiliated with the PGA Tour include the Asian Tour and Middle East North Africa (MENA) Tour, both of which receive Saudi funding.

The Antitrust Lawsuit Early Stages

By mid-2022, LIV had recruited to its circuit five of the ten golfers who had earned “player impact” bonuses on the PGA Tour. According, to media reports the fees LIV promised to those golfers were astronomical: Phil Mickelson at $200 million, Dustin Johnson at $150 million, and Bryson DeChambeau at $100 million. ¹⁰ LIV was well on its way to filling its ranks for its 48-player circuit when the PGA Tour started suspending members who played in LIV’s early exhibition tournaments. In August 2022, on the eve of the rankings-critical FedEx Cup series of PGA Tour events, 11 LIV players led by Mickelson filed a federal antitrust lawsuit and a motion for a temporary restraining order (“TRO”) to enjoin the PGA Tour’s ban and compel it to allow LIV golfers into the FedEx Cup.¹¹

The antitrust complaint¹² alleged a market for the services of elite professional golfers, which the PGA Tour allegedly monopolized (or monopsonized), in violation of the U.S. Sherman Act §2, by requiring exclusive commitments that barred Tour members from playing in conflicting events and participating in competing golf media programming.¹³The complaint also alleged the PGA Tour violated Sherman Act §1 by conspiring with other industry participants to throw up roadblocks to LIV Golf’s successful entry.¹⁴

The LIV golfers’ TRO motion argued that they would be irreparably harmed if they were not permitted to participate in PGA Tour events pending the outcome of their antitrust claims. That argument failed and the motion was denied. The U.S. district court found that the LIV golfers did not overcome the high bar for such relief, primarily because they had not established irreparable harm. In an August 10, 2022 order¹⁵,U.S. District Judge Beth Labson Freeman found that the LIV golfers have not been locked out of their sport or its lucrative payouts of prize money and sponsorship fees. To the contrary, Judge Freeman emphasized that the LIV golfers are earning significantly more money than they ever did on the PGA Tour, and that they calculated the money they would lose from missing the FedEx Cup when they negotiated their contracts with LIV Golf. In addition, the LIV golfers and their expert witnesses described LIV events as “elite golf” that equals if not exceeds PGA Tour events in offering meaningful competition to the players and fans. That position undermined the golfers’ portrayal of the Tour as possessing and abusing monopolistic control over the market for elite golfers’ services.

Without interim relief, the LIV golfers’ only path back to the PGA Tour was litigating their antitrust claims over the many months or years it would take to get to a jury and hopefully a verdict in their favor. That prospect led all but three of the golfer plaintiffs to drop out of the lawsuit, and the LIV Golf entity itself to join as a plaintiff.¹⁶ The lawsuit’s emphasis then shifted away from monopolization of the upstream market for professional golf services, although the antitrust treatment of a tour’s exclusive contracts with athletes who are independent contractors remains a live issue in the case. However, the amended complaint focuses on the downstream promotion of elite professional golf, and PGA Tour actions that allegedly prevent LIV from accessing the business relationships essential to entering and succeeding in that golf market.¹⁷

For example, the amended complaint alleges that the Tour has conspired with other tours and the majors to exclude LIV golfers. As of this writing, all four of the major tournaments have announced that LIV golfers will continue to be eligible to play on the same qualifying grounds as any player. The amended complaint also alleges that the PGA Tour has conspired with the OWGR to block LIV events from contributing to player rankings. Perhaps in response to that allegation, PGA Tour and DP World Tour representatives on the OWGR Board of Directors have recused themselves from reviewing LIV Golf’s application for event ranking points.

PGA Tour Goes on the Offensive

After its first significant victory in the lawsuit—the denial of the TRO—the PGA Tour went on the offensive. It filed a formal Answer¹⁸ with the court that sets forth its legitimate business reasons for establishing and enforcing its regulations, briefly, to protect sponsors, media partners, and revenue streams, and to reward and incentivize players.¹⁹ The Answer further attempts to discredit LIV Golf as an under-strategized offering that is seeks to free-ride on the PGA Tour’s success by forcing the Tour to include LIV golfers so they can retain their rankings, celebrity, and fan appeal, which LIV Golf can then exploit. The PGA Tour points out that LIV’s success so far contradicts its monopsony allegations, given how many players it has been able to attract with its millions in guaranteed payouts. Also expect the PGA Tour to lean on the perception that LIV Golf is the latest example of the way oil-rich Gulf monarchies, like the Kingdom of Saudi Arabia, use their vast wealth to invest in sports and cultural institutions in hopes of sanitizing their reputation for human rights abuses, a.k.a. “sportswashing.” The PGA Tour has alleged that LIV Golf is responsible for its failure to connect with golf audiences because of their distaste for association with the Saudis.

In addition, the PGA Tour lodged a counterclaim against LIV Golf for tortious interference with contract in luring away Tour golfers with false promises of continued access to Tour events, through antitrust litigation if necessary. According to the counterclaim, LIV knew full well that by suspending members who play for conflicting events without permission, the Tour neither engaged in anticompetitive conduct nor violated its own rules. LIV’s duplicity is allegedly exemplified by the fact that its own multiyear contracts impose far more restrictive obligations than the PGA Tour, including an absolute ban on participating in conflicting events with no possibility of getting an exemption.

Pretrial Discovery and Adding LIV’s Saudi Backers to the Lawsuit

Based on the urgency expressed in LIV Golf’s pleadings, District Judge Freeman set an ambitious litigation schedule, initially calendaring the trial date for January 2024, breakneck speed for an antitrust lawsuit that examines an entire industry. Pretrial discovery under permissive U.S. federal court rules has proceeded, with oversight delegated to Magistrate Judge Susan Van Keulen. And she has been kept busy as the process has been bedeviled by disputes over confidentiality demands²⁰, the proper scope of discovery requests, ²¹ and access to discovery from non-parties.²² At one point, LIV Golf attempted to subpoena high-profile members of Augusta National Golf Club, the host of the Masters Tournament, alleging they were doing the PGA Tour’s dirty work by trying to influence U.S. government officials not to investigate the Tour. Among those named in the Augusta subpoena was former U.S. Secretary of State Condoleezza Rice. Judge Van Keulen quashed that subpoena as overly burdensome.²³

By contrast, Judge Van Keulen upheld a non-party subpoena that the PGA Tour served on the Saudi PIF and its governor, Yasir Al-Rumayyan.²⁴ The Saudis hotly contested the subpoena as a violation of the U.S. Foreign Sovereign Immunities Act (“FSIA”), which is designed to preserve international comity by limiting the jurisdiction of U.S. courts over foreign governments.²⁵ Judge Van Keulen rejected that argument, finding that, although PIF and its governor are agents of the Saudi government, they have been sufficiently involved in the founding, funding, oversight, and operations of LIV Golf that they are subject to non-party discovery under the “commercial activity” exception to the FSIA.²⁶ On reconsideration, Judge Freeman affirmed that ruling,²⁷and the Saudi parties are now appealing to the Ninth Circuit Court of Appeals.

Despite these discovery hiccups, the PGA Tour has learned enough about Saudi involvement in LIV Golf that it amended its counterclaim to add the PIF and Al-Rumayyan as defendants who should also be held liable for tortious interference with contract. The court approved the amended pleading,²⁸subject to a Saudi motion to dismiss those claims, again based on FSIA immunity. The PGA Tour will no doubt again argue the Saudis must submit to the court’s jurisdiction under the FSIA’s “commercial activity” exception, and its chances look good given the earlier ruling that authorized non-party discovery against the Saudis.

Saudi resistance to the court’s jurisdiction is grounded in its strict secrecy laws which punish by imprisonment those who reveal the confidential workings of government, even when compelled to do so by legal process. The Saudis may also be experiencing some buyer’s remorse here, having miscalculated when they decided to fund the antitrust lawsuit in the first place, not realizing how deep they would be dragged into the muck of American adversarial litigation. Permissive U.S. discovery rules also risk unearthing details about other Saudi investments, and perhaps the Kingdom’s attempts to influence U.S. politics. If the Saudis are held subject to U.S. court jurisdiction, either to provide non-party discovery and/or directly defend against the counterclaim, their incentives for settling this case multiply.

The Future of the Lawsuit and Professional Golf

Because of delays in discovery, especially from the Saudi entities, Judge Freeman has now vacated the January 2024 trial date, and targeted May 2024 instead. Meanwhile, depositions (pretrial examinations of witnesses under oath) have begun, and counsel anticipates some 80 witnesses will ultimately be deposed, including many professional golfers, whether or not named as parties in the lawsuit. Once discovery is concluded, the pretrial evidentiary record will tee up summary judgment motions, in which the parties will each attempt to convince the court that they are entitled to judgment as a matter of law and can dispense with a jury trial at least as to some issues and claims.

Further slippage in the trial date seems inevitable, especially in light of the Saudi decision to contest the court’s jurisdiction over it both as non-party deponents in the antitrust suit and as defendants in the Tour’s tortious interference counterclaim. LIV Golf sought to keep its antitrust claims moving forward by asking the district court to bifurcate the counterclaim and try it separately at a later date. Because both sets of claims require overlapping evidence and witnesses, the court denied this request as a matter of judicial economy.

One possible outcome of the lawsuit is that LIV Golf and the PGA Tour negotiate a settlement that provides for co-existence. But a significant barrier would be the issue of reinstating LIV golfers who have pocketed Saudi riches, as they have generated much resentment among the golfers who stayed loyal to the Tour. Another impediment to settlement is how to effectuate co-existence of the two golf circuits without engaging in cartel-like conduct that might spawn new antitrust risk.

Meanwhile, the world of professional golf moves forward. Beyond responding to the lawsuit, the PGA Tour has had to respond to the new competitive environment. And its response to some extent refutes the need for antitrust remedies to thwart the Tour from continuing to exploit its alleged monopoly power. To retain its members who were being offered huge paydays by LIV Golf, the PGA Tour has made sweeping changes to its schedule, structure, and compensation. Beginning with the 2022-23 season, PGA Tour members and other exempt players are guaranteed $500,000 against earnings, whether or not they make a “cut” in any tournament. This amount is not a salary, but rather a base level which provides $500,000 against any prize money earned that year, to defray the expenses of competing on the Tour. The Tour also expanded its Player Impact Program, which debuted in 2021, to award bonuses totaling over $100 million to the 20 most popular players for boosting fan engagement and publicity.

Starting in 2024, the PGA Tour is creating eight designated events with limited fields, no cuts, and $20-million purses to bring the top players together more often—and reward them more handsomely. It is structuring the events so that all Tour members will have ways to play their way in, to retain the intensity and competitive integrity that the Tour claims differentiates it from LIV’s 54-hole, no-cut events, and guaranteed salaries. No doubt the Tour will continue to evolve, with every new strategy developed under the shadow of antitrust and every new business practice designed in part for how it will play to an antitrust jury.

This article was first published on the LawInSport blog. The original is available to view here.

Written by: Jodi S. Balsam
Jodi is Professor of Clinical Law and Director of Externship Programs at Brooklyn Law School

Article Sources

¹ Anushree Dinesh Burad, ‘LIV Golf salary: How much do golfers get paid?’, SportsKeeda, published on 7 March 2023, https://www.sportskeeda.com/golf/liv-golf-salary-how-much-golfers-get-paid (last accessed 10 April 2023)
² Adam Kilgore & Matt Bonesteel, ‘PGA Tour suspends players in Saudi-backed event as golf’s discord deepens’, Washington Post, published on 9 June 2022, https://www.washingtonpost.com/sports/2022/06/09/pga-suspension-liv-golfers/ (last accessed 10 April 2023)
³ Complaint in Mickelson v. PGA Tour, Inc., 5:22-CV-04486 (N.D.Cal. Aug. 3, 2022) (case since re-captioned Jones v. PGA Tour, Inc.), https://www.law360.com/articles/1518020/attachments/0 (last accessed 10 April 2023).
⁴ Carola Binney, ‘Teeing Up For A Competition Lawsuit? The PGA Tour’s Refusal To Release LIV Golf Invitational Hopefuls’, LawInSport, published on 7 June 2022, https://www.lawinsport.com/topics/item/teeing-up-for-a-competition-lawsuit-the-pga-tour-s-refusal-to-release-liv-golf-invitational-hopefuls (last accessed 10 April 2023)
⁵ See generally 2022-2023 PGA Tour Player Handbook (for instance, Regulation V.A. and V.B. of the 2022-2023 PGA Tour Tournament Regulations), https://qualifying.pgatourhq.com/static-assets/uploads/2022-2023-PGA-TOUR-HBandRegs-DEC%202022.pdf (last accessed 10 April 2023)
⁶ Regulation V.A.3. of the 2022-2023 PGA Tour Tournament Regulations, available here: https://qualifying.pgatourhq.com/static-assets/uploads/2022-2023-PGA-TOUR-HBandRegs-DEC%202022.pdf (last accessed 11 April 2023)
⁷ ‘Dustin Johnson confirms PGA Tour resignation and Ryder Cup ineligibility: ‘LIV format is true test’, Sky Sports, published on 6 August 2022, https://www.skysports.com/golf/news/12176/12629313/dustin-johnson-confirms-pga-resignation-and-ryder-cup-illegibility-liv-format-is-true-test (last accessed 10 April 2023)
⁸ Joel Beall, ‘What LIV Golf’s TV deal means’, Golf Digest, published on 21 January 2023, https://www.golfdigest.com/story/liv-golf-tv-deal-beall-2023 (last accessed 10 April 2023)
⁹ In front of Sport Resolutions, an independent private dispute resolution tribunal. See Poulter, Jauregui and Harding v PGA European Tour, (Sport Resolutions, April 3, 2023), https://www.sportresolutions.com/decisions/view/golfers-v-pga-european-tour (last accessed 10 April 2023)
¹⁰ Anushree Dinesh Burad, ‘LIV Golf salary: How much do golfers get paid?’, SportsKeeda, published on 7 March 2023, https://www.sportskeeda.com/golf/liv-golf-salary-how-much-golfers-get-paid (last accessed 10 April 2023)
¹¹Homero De la Fuente & Jacob Lev, ‘Phil Mickelson, 10 other LIV golfers file antitrust lawsuit against PGA Tour’, CNN, published on 3 August 2022, https://edition.cnn.com/2022/08/03/golf/liv-golfers-sue-pga-tour-spt-intl/index.html (last accessed 10 April 2023)
¹² Complaint in Mickelson v. PGA Tour, Inc., 5:22-CV-04486 (N.D.Cal. Aug. 3, 2022) (case since re-captioned Jones v. PGA Tour, Inc.), https://www.law360.com/articles/1535281/attachments/0.
¹³15 U.S.C. § 2.
¹⁴15 U.S.C. § 1.
¹⁵ Mickelson v. PGA Tour, Inc., No. 22-CV-04486-BLF, 2022 WL 3229341 (N.D. Cal. Aug. 10, 2022).
¹⁶ The LIV golfers who abandoned the lawsuit did not abandon the LIV Golf tour and continue to play in that circuit, with no access to PGA Tour events. And they are nonetheless considered witnesses in the antitrust litigation and will have to turn over documents and sit for depositions.
¹⁷ Amended Complaint in Jones v. PGA Tour, Inc., (N.D. Cal. Aug. 26, 2022), https://www.law360.com/articles/1528971/attachments/0
¹⁸ An ‘Answer’ refers to the formal written statement by a defendant in a civil case that responds to a complaint, articulating the grounds for defense. Read more here: https://www.uscourts.gov/glossary (last accessed 10 April 2023)
¹⁹Answer and Counterclaim in Jones v. PGA Tour, Inc. (N.D. Cal. Sept. 28, 2022), https://www.law360.com/articles/1535281/attachments/0
²⁰ Alex Miceli, ‘Judge Rules That PGA Tour Can Depose LIV Golf and Its Leaders’, Sports Illustrated, published on 17 February 2023, https://www.si.com/golf/news/judge-rules-that-pga-tour-can-depose-liv-golf-and-its-leaders
²¹ Alex Miceli, ‘LIV Golf Lands a Legal Win vs. PGA Tour in Battle for Information’, Sports Illustrated, published on 25 October 2022, https://www.si.com/golf/news/liv-golf-lands-legal-win-vs-pga-tour-in-battle-for-information
²²Doug Ferguson, ‘Judge denies LIV plea to expand discovery to Augusta members’, Associated Press, published on 31 January 2023, https://apnews.com/article/sports-legal-proceedings-us-department-of-justice-tom-cotton-condoleezza-rice-f418ae0b51f47bbc8778bd0382453db3
²³Order in Jones v. PGA Tour, Inc., No. 22-CV-04486-BLF (N.D. Cal. Jan. 30, 2023), https://www.law360.com/articles/1570824/attachments/0 (last accessed 10 April 2023); Doug Ferguson, ‘Judge denies LIV plea to expand discovery to Augusta members’, Associated Press, published on 31 January 2023, https://apnews.com/article/sports-legal-proceedings-us-department-of-justice-tom-cotton-condoleezza-rice-f418ae0b51f47bbc8778bd0382453db3
²⁴ Jones v. PGA Tour, Inc. (N.D. Cal. Feb. 9, 2023), https://www.law360.com/articles/1577296/attachments/0
²⁵ 28 U.S.C. § 1602 et seq. The status of the PIF as a government arm may prove to be an issue in the UK in relation to the PIF’s ownership of Newcastle United. While taking over Newcastle, the PIF reportedly provided guarantees that it is distinct from the Saudi government, guarantees which may be now void as they themselves have argued the opposite in the US courts.
²⁶ 28 U.S.C. § 1605(a).
²⁷ Order in Jones v. PGA Tour, Inc., No. 22-CV-04486-BLF (N.D. Cal. April 6, 2023), https://www.law360.com/articles/1594786/attachments/0
²⁸ Jones v. PGA Tour, Inc., No. 22-CV-04486-BLF, 2023 WL 2173417 (N.D. Cal. Feb. 21, 2023).

LIV Golf v. PGA Tour and the Future of Professional Golf

The PGA Tour’s Financial and Regulatory Model

How Does LIV Golf Differ from the PGA Tour

Other Participants In the Professional Golf Ecosystem

The Antitrust Lawsuit Early Stages

PGA Tour Goes on the Offensive

Pretrial Discovery and Adding LIV’s Saudi Backers to the Lawsuit

The Future of the Lawsuit and Professional Golf

Article Sources

Related Posts

Bad Air In La: Tyrod Taylor’s Punctured Lung And The Law

Collegiate-Athletes, On the Brink of Payment?

NFL-DirecTV Sunday Ticket: (Maybe) Too Big To Fail

Crime and Punishment: What Options do Sports Leagues Have When Players Are Suspected of Committing a Crime?