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2015] THE NO-FANTASY LEAGUE 73
manipulate the spread.
119
Numerous such scandals have implicated
National Collegiate Athletic Association (hereinafter “NCAA”)
men’s basketball teams. Of note, the 1950-51 CCNY scandal impli-
cated thirty-three players involved in point shaving among seven
schools: the City University of New York, City College (the 1950
champions of both the NCAA Tournament and the National Invita-
tional Tournament); New York University; Long Island University;
Manhattan College (all four of these within the New York City area);
Bradley University in Peoria, IL; the University of Toledo in Toledo,
OH; and the University of Kentucky in Lexington, KY.
120
The after-
math of the CCNY scandal was profound. The 1951 NCAA Tourna-
ment’s Most Outstanding Player, Bill Spivey, would never again play
for the University of Kentucky,
121
and he would later find himself
blackballed by the National Basketball Association (hereinafter
“NBA”), under President Maurice Podoloff.
122
A subsequent scandal
in 1961 was the “last straw” for Madison Square Garden, as the
NCAA Tournament would not return to New York City until 2014.
123
Later, members of the 1978-79 Boston College basketball team faced
RICO convictions for ensuring pre-planned outcomes (either allowing
the other team to cover the spread, or, as an alternate strategy to re-
duce suspicion, to affirmatively beat the spread) in exchange for cash
119. “The spread” (sometimes called “the line”) refers to an automatic handicap that bookies
place on each game, in order to provide more equitable odds between the teams by offsetting the
superior team’s inherent advantage. For example, if the Green Bay Packers (-13.5) were to play
against the Minnesota Vikings, the spread would be 13.5 points. In this example, bets in favor of
the favorite (the Packers), would have to “give” 13.5 points to the Vikings, and bets in favor of
the Vikings would “‘take’ the points.” In other words, even if the Packers were to win the actual
game, bettors would need the Packers to “cover the spread” by beating the Vikings by more than
13.5 points, in order to return winning bets. Fractional spreads are often used in order to elimi-
nate the possibility of “pushes,” which are ties according to sports books. When pushes occur,
bookies must refund all bets, yielding no winners or losers, and they also must bear the costs of
overhead. Accordingly, “point shaving,” or “manipulating the spread,” refers to deliberate ef-
forts to guarantee outcomes against the spread, with the reward of a financial benefit from the
enriched bookie.
120. Joe Goldstein, Explosion: 1951 scandals threaten college hoops,
ESPN C
LASSIC
(Nov. 19,
2003), http://espn.go.com/classic/s/basketball_scandals_explosion.html.
121. Bill Spivey Barred By Kentucky Board,
P
ITTSBURGH
P
OST
-G
AZETTE
, Mar. 3, 1952, at 23.
122. Podoloff Won’t Approve Contract For Bill Spivey,
T
HE
F
LORENCE
T
IMES
, Sept. 1, 1960,
at 3; see also Frank Litsky, Bill Spivey, 66, Kentucky Star Implicated In Scandal of 1950’s,
T
HE
N
EW
Y
ORK
T
IMES
(May 10, 1995), http://www.nytimes.com/1995/05/10/obituaries/bill-spivey-66-
kentucky-star-implicated-in-scandal-of-1950-s.html.
123. Seth Berkman, Remembering a Tournament ‘Final’ at the Garden,
T
HE
N
EW
Y
ORK
T
IMES
(March 28, 2014), http://www.nytimes.com/2014/03/29/sports/ncaabasketball/billy-packer-
relives-last-madison-square-garden-tournament-game.html?_r=0.