27/11/2023 38comments  |  Jump to last

Evertonians must prepare for a protracted battle in the public sphere. This article assembled by Mike Gow at The State of Football substack site provides eight potential arguments or grounds for the Appeal – and a clarion call to keep the heat on the Premier League.

Battle Plan: Our Line of Attack

Each of the eight Grounds for Appeal is laid out below. The order is deliberate and dictated by the amount of damage each would inflict on the Premier League's Independent Commission (PLIC) Judgement.

Grounds No 1-4 challenge the very notion that any sanction must take “sporting advantage” into consideration.

Ground No 5 uses the Premier League’s own argument, that “sporting advantage” is impossible to quantify, against the PLIC judgement. This is a back-up argument in case 1-4 are all rejected.

Article continues below video content


Ground No 6 focuses on the logical fallacy in the accusation that Everton continued trading players and this was the primary cause in their breach of PSR.

Ground No 7 highlights the moral hazard on display in the PLIC's sanction which punishes supporters and the team, not those responsible for the financial mismanagement of Everton FC.

Ground No 8 is the final appeal against the excessive severity of the sanction imposed – demonstrable when compared against historical cases of penalties imposed for financial problems, and with the penalty imposed in the precedent case (EFL vs SWFC) after appeal.

Our objective here is to start with potential strikes that will cause the most damage to the PLIC’s reasons for imposing such a harsh penalty.

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» Read the full article at The State of Football



Reader Comments (38)

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Barry Hesketh
1 Posted 27/11/2023 at 17:38:54
Mike Gow is dead right when he says Evertonians must prepare for a protracted battle. This ain't over.

Tony Everan
2 Posted 27/11/2023 at 18:29:00
Barry. I’ve been following Mike Gow on Twitter, he gets down to the detail and delivers it in a clear way. These are very good arguments, you would hope Everton’s legal team are already all over it and more besides.

Just in case they aren’t, they better have a good read of Mike’s epic post.

Michael Kenrick
3 Posted 27/11/2023 at 20:05:36
Barry,

Thanks for flagging this one up. I would never have seen it. Presumably you got an email notification if you were subscribed?

Sorry, I plagiarized your original post for the piece so please put up anything you want to say about this and I'll swap it in @1.

Michael Kenrick
4 Posted 27/11/2023 at 20:18:49
Some really interesting stuff on the thorny question of 'sporting advantage':

Pointing out the deductive fallacy that underpins the claim of “sporting advantage” in the EFL vs Sheffield Wednesday FC is important because, if it is deemed to be a flawed argument, the PLIC is under no regulatory obligation to follow it as precedent – because EFL vs SWFC is only a persuasive precedent from a different regulatory jurisdiction.

Billy Roberts
5 Posted 27/11/2023 at 20:47:13
Point 9),

How can we just let the Player X situation float on by?

We, through no fault of our own, lost a crucial international midfielder for 2 seasons. We were at a sporting disadvantage.

We lost the facility to sell this player for let's say £15-20 million and we paid his wages... all this time.

We have incurred all of the penalty points for an overspend virtually of the same amount?

How can this not be a contributing factor to our financial state? How can this not be a mitigating factor? Have I missed something? I am baffled by this being brushed aside.

Phil (Kelsall) Roberts
6 Posted 27/11/2023 at 20:54:33
This alongside that City played Mendy all the time he was under investigation including in a Champions League Final.

His case was innocent at trail — ours was no case presented.

Anthony Hawkins
7 Posted 27/11/2023 at 21:26:21
I have to admit, non of it seems water tight and most seems very subjective. I was hoping there would be some extremely robust, plausible and forward-thinking challenges to bring to the table, rather than cap in hand almost apologetic positioning.

1 to 4 on sporting advantage is assumed, presumed and expected based on having continued to spend on players we expected to position us higher up the table, yet unfortunately didn't. indeed, had we finished 8th and above, we wouldn't have a case to answer.

5 is irrelevant due to 1 to 4 and is utterly subjective.

6 if not presented correctly could display the naivety that got us in this position. Focusing on the change of rules previously enjoyed by other clubs, the interest payments accommodated in the accounts as a deduction. If not, this would highlight that the club didn't understand the financial rules and did indeed continue spending beyond their means because the additional money wasn't there - or spending on a hope and assumption that we'd finish higher.

7 & 8 I agree with fully.

1 to 6 seriously risk exposing the club and being easily dismissed.

Why are the club not rigorously defending the position on player X?

I really hope the legal representatives buff up and take a financial representative with them.

Russelll Smith
8 Posted 28/11/2023 at 09:03:31
The results over the weekend should demolish the false claims that we will be okay with a 10-point deduction this season. We are now 8 points below Bournemouth with a run of difficult fixtures to come. We need to completely overturn the 10pt deduction or we will be in a massive relegation battle again.

I read Mike Gow's “The State of Football” on X detailing what our counter arguments should be in our appeal. It is the best “legal” argument I have read in all the things I have seen published since the points deduction.

Surely our legal team will be using a similar approach in the appeal. His point that P&S is only mentioned 8 times in the PL rules and always in relation to regulating financial matters and no reference to sporting advantage has got to be a central plank in our defence.

If this can be successfully argued, we should not be deducted any points and the case for others to sue us will disappear. We will get a fine which won't help with next year's P&S submission but it will set a precedent going forward. We will probably face continuing fines year on year until we sell some of our best players to balance the books.

Jerome Shields
9 Posted 28/11/2023 at 09:39:14
It seems to me that the legal team representing Everton got the same impression of the Everton hierarchy as everyone else. That they were leaderless, hands off, of poor management ability, and self-preserving.

They may even been led to believe that the Premier League would go easy on Everton. The legal team then just went through the motions at the commission hearings and collected their fat fees.

It was pointed out repeatedly on ToffeeWeb how blasé Everton were about controlling the narrative before the commission and quite frankly their presentations to the commission amounted to a surrender flag.

Contrast this with Man City who never recognised the validity and implementation of the Premier League rules, which are falling about full of holes before our eyes. Man City are right in what they are doing, not working with the Premier League from the start and their Saudi owners talking to the government, via a visiting government minister.

The other factor that was evident after the hearings to us was that rules were being made up and changed during the process. I find it hard to believe that Everton and its legal team, being a party involved in the private hearing, were not aware of this.

What's more, they did not raise any objections, now saying they only knew about them this a week after the findings of the commission. I do believe this.

Brian Harrison
10 Posted 28/11/2023 at 10:00:57
As well as the points deduction handed out, the Premier League will also determine whether 777 Partners are fit and proper people to own Everton.

I think with this we are between a rock and a hard place: they don't seem fit and proper listening to supporters of clubs they do own. But if the Premier League decide they don't meet the fit and proper test, does that mean the club will have to apply for administration, as it's reported that 777 Partners have put in a substantial amount of money to pay for the day-to-day running of the club, and presumably if they don't get to own the club, they will want their money back.

Seeing Moshiri is unwilling to finance the club any further, I can't see how we avoid going into administration.

Alan J Thompson
11 Posted 28/11/2023 at 10:34:56
I would also like to see us ask that no penalty is implemented until investigations that were underway into other clubs are complete as, if it was deemed that they had an unfair advantage by their actions, that this could have had an effect on all other clubs' results.
Vince Hindson
12 Posted 28/11/2023 at 11:06:23
During all of the debate about reducing the punishment, I'm surprised that no-one has considered that the Premier League and commission may review the appeal, double down, and increase the punishment to 12 points.
Mark Taylor
13 Posted 28/11/2023 at 11:12:25
I've said elsewhere that the article referenced is the first serious attempt I've seen to create a plan to either overturn the punishment or, at the least, get it reduced on appeal.

Certainly more powerful than Burnham's letter with it's pointless 'we're a victim' conspiracy theories. I like the combination of points 3 and 8, these seem the most pertinent.

Although a name does not necessarily imply intent, I'd also note the Premier League have called these rules 'Profitability and Sustainability'. Not a derivative of 'Financial Fair Play' which more indicates a specific intent.

The implication of the P&S name is that clubs don't go bust and the way the rules are set supports this, with a target of zero loss and the hard ceiling of £105M over a limited period, the latter effectively accepting the need to invest at certain stages of the cycle.

That being so, a points deduction as the assumed punishment becomes even more questionable, as would a fine. It would be far more suited to have a transfer embargo or a wage limit of some sort as punishment.

Finally, and perhaps most importantly, Brian @10 articulates what seems to me to be the greatest risk. That 777 are denied the chance to complete the sale.

In that scenario, unless another suitor materialises pretty much instantly, we will indeed be in administration, technically bankrupt. That will be the end of the club as we know it and it will be a long hard road back from there. See Portsmouth...

Jim Wilson
14 Posted 28/11/2023 at 11:16:54
Why is the precedent case, Sheffield Wednesday, from a different league and not the Leicester City case in the Premier League?

The glaring discrepancy for me is the 'Breakaway 6' receive a fine for a far worse offence with the comment the fans should not be punished.

It shows the Premier League and Commision have gone completely over the top with our punishment with no concern for the Everton fans.

George McKane
15 Posted 28/11/2023 at 11:38:23
Of course, we all know this and I am stating the obvious – it's good for me – but although the situation is not something we wished or asked for and is as well known as quite disgraceful and unjust, now is the time to use this challenge to our advantage and galvanise our thinking and actions into becoming "The Heroes" of the current situation.

Most clubs and their supporters (from what I have read) outside "the smug self-centred six" dislike not only this "judgement" but the Premier League, Sky, Media Big 6 Phobia.

This is our chance, during what has been for us a very poor period in the Premier League, to challenge and lead the fight against corruption and battle to return football to where it belongs.

I am not naive enough and am old enough to not know there has always been some collusion and corruption in football but not to this barefaced extent of now. Let's take the lead and go on the offensive.

From recent days, I can see we, and other clubs' supporters, are responding and even the Media seem to be behind us.
Lead The Way Everton.

Everton The Club (The Supporters) who broke the Premier League and saved football.

Robert Tressell
16 Posted 28/11/2023 at 11:42:49
Jerome, this is what will have happened with the legal team:

- they would have advised the club on the full breadth of strategy, options and risk;

- the club would have taken it on board and decided on an approach.

That is how businesses engage with professional advisers. It wouldn't just be lawyers either. I expect something so serious would have called in a variety of help (and input from the non-executive directors).

Clearly the output is botched as a result of misjudgement.

It looks like we expected a lighter punishment – and were trying to achieve that through good behaviour.

We tarnished our own good behaviour position through feigning transparency.

Finally, the club misjudged due to lack of precedent for something so harsh.

That last aspect is key. We've obviously played the game poorly in hindsight but the authorities have absolutely killed us for a relatively minor breach (that we've obviously been managing very carefully through sales of Richarlison and Gordon and Kean).

I think we are probably being used as a guinea pig for the bigger Man City and Chelsea indiscretions and the looming possibility of an independent regulatory body

Behind the scenes, it might be that the club had been completely misled by the current authorities – and coaxed into an approach which has backfired.

This will all play out in an appeal if so.

Shockingly corrupt, though, is how I view it.


Anthony Hawkins
17 Posted 28/11/2023 at 12:26:04
I don't get why the club are laying down and simply accepting the outcome. What I'm seeing is more like a plea bargain than a formal appeal.

Why not bring into question previous guidance? Why capitulate when pushed back when the commission say "we don't see it that way"? Why not respond with 'how can you say that?' or question the root of the investigations thoughts?

Does the club know something we don't? eg, potential incursions for City and Chelsea? Or are the club hoping to avoid a deeper investigation into the closet?

John Hall
18 Posted 28/11/2023 at 13:11:40
Walked in with white hankies in the air. Dumb as they come.

It was well publicized before the lynching what the outcome would be.

Should have been placards indicating 'Not Guilty' instead of white flags pleading for a lesser punishment.

Just about sums up all the dopes and dickheads who have been at the helm for the past 20 years.

What type of experts mounting a defense allow a bunch of amateurs to courteously go in front of a so-called independent committee who had already sentenced them before they arrived?

Incompetence does really run through this club. Is there not such a thing as legally challenging a decision which was made and administered by a corrupt kangaroo court?

Might be a good idea if we could employ a proper respected top legal eagle instead of the no-win no-fee idiots that allowed us to go in for a 10-quid defense.

John Keating
19 Posted 28/11/2023 at 13:14:10
Though not of the persuasion, the whole thing seems quite "Masonic".

Everything behind closed doors, leading remarks by interested parties prior to and during the "closed trial".

Surely this is an ideal case to submit to the Court of Arbitration for Sport?

John Hall
20 Posted 28/11/2023 at 13:22:11
John @19.

I seem to remember having read that the decisions of the kangaroo committee are not allowed to be taken before the Court of Arbitration.

Somebody please correct me if I am wrong as this would seem our only avenue to seek a lesser sentence even though we did stupidly plead guilty.

Will Man City, Spurs and Chelsea plead guilty to their charges?

Never.

Brian Williams
21 Posted 28/11/2023 at 13:46:45
Anthony #17.

The club is launching an appeal I believe.

John #18,

There was no other plea the club could make because the club was/is quite clearly and without doubt guilty of the charge of breaking P&S rules.

Anthony Hawkins
22 Posted 28/11/2023 at 13:47:22
John @20,

Just because the question and approach was raised to the Premier League doesn't instantly mean we're guilty.

Had the club denied wrong-doing and shared they'd been open with the Premier League, they could and should have said "This is our version of events" and "we approached it following these guidelines."

If the handling of finances changed mid-season, they could call that out as a definitive reason why the variance existed. It wasn't that they had negligently ovespent or not considered the issue, it was the guidance changed and the club did everything they could to claw it back. Power play.

Instead, they went whimpering and pleading 'please don't hurt us!'.

It should be the club asking for a valid reason why they should be punished as opposed to giving them every reason to be punished. Even when the verdict and punishment was given, there should have been an immediate challenge against using previous precedence and holding the judgement to account.

The whole process has been set up specifically for this case, with conflict of interest for individuals and adjusted part way through. That should be enough to get it thrown out.

Now, do we have a case to answer? Yes, but not in isolation from the broader Premier League and clubs.

Danny O’Neill
23 Posted 28/11/2023 at 13:56:27
This is not over. It was interesting hearing the Wolves supporters singing the same chant.

The Premier League has opened their own can of worms and set their own precedent.

Fight them, Everton. Because if this is what they have set as an example, let's see those grey suits apply equal measures to others who have committed worse "crimes" than us. Or they reduce the punishment. I don't believe many doubt we should be punished. But then so should others.

Portsmouth? We are not Portsmouth. We are Everton. Loud and Proud. There is no way we are following their pathway.

Keep going, Blues. Be vocal, but keep it sensible. Only the cousins get away with being able to get away with misbehaviour. Give the authorities one excuse and they will jump all over us.

Nottingham on Saturday. Believe.

Christopher Timmins
24 Posted 28/11/2023 at 14:18:15
Danny

Nottingham Forest on Saturday and three points to be added to our total.

Michael Kenrick
25 Posted 28/11/2023 at 14:47:36
The Premier League Handbook says the Appeal is final, but it's qualified:

W.79. Subject to the provisions of Section X (Arbitration) of these Rules, the decision of an Appeal Board shall be final.

I think after the appeal, the next step would be arbitration under the Premier League's Rules (Section X of the Handbook). And then this:

Challenging the Award

X.37. Subject to the provisions of sections 67 to 71 of the Arbitration Act 1996, the award shall be final and binding on the parties and there shall be no right of appeal. There shall be no right of appeal on a point of law under section 69 of the Act.

In the event that a party to arbitration under this Section X challenges the award, whether in the English High Court or any other forum, it shall ensure that the League is provided with a copy of any written pleadings filed and/or evidence adduced as soon as reasonably practicable after their/its filing.

That does seem to leave an opening for external court action — if Everton have the balls and the money — neither of which have been exhibited to this point. I mean, admitting guilt… how fucking stupid can you be???

No specific exclusion of CAS that I could find.

Andrew Ellams
26 Posted 28/11/2023 at 15:03:17
I see the IFAB have decided to trial sin bins in professional football for offences such as dissent.

One more way to push the game in favour of the big clubs.

John Hall
27 Posted 28/11/2023 at 15:06:53
Excellent clarification.

Thank you, Michael.

Danny O’Neill
28 Posted 28/11/2023 at 15:21:02
Christopher,

Not sure if said it here or on another ther thread.

I won't have to stand in the open corner with no roof that used to be the away end and climb the floodlight to get a decent view.

Fast approaching match mode. What has gone has gone.

Someone more educated can explain but I'm reading that Saturday's opponents are next in line.

Apparently their P&S pre tax loss tripled to over £46M.

Fight, Everton, and call them out now they've singled us out.

Barry Hesketh
29 Posted 28/11/2023 at 15:44:25
According to a tweet by Martyn Ziegler of The Times, in February 2023:

Man City latest: under Premier League rules the club will not be able to appeal any sanction to the Court of Arbitration for Sport (which overturned the UEFA ban)

I've seen similar things posted elsewhere about Everton too, but like Michael points out, nothing appears to be officially written down.

Having said that, as the Premier League didn't expect clubs to breach the Profit and Sustainability Rules and had no set plan for punishment if they did, it wouldn't surprise me if the pathway to bring in the Court of Arbitration for Sport, isn't quite as blocked as the Premier League would like us all to believe?

Mark Taylor
30 Posted 28/11/2023 at 16:39:13
Anthony @22 (and others),

Bear in mind this was an extended process, with several submissions, counters and so forth. It is all detailed in the report, if you've read it.

Initially we did claim we had complied. But then evidence emerged that we hadn't. For example, that the loan interest from Metro and R&MF could not be deducted as a stadium expense for the very simple reason the loan agreements clearly stated it was for the club's working capital.

Embarrassing, really. Hence when it came to the hearing itself, we had reached the point where we had no choice but to admit we were over and had breached.

The anger here would be better directed at our useless owner and his totally dysfunctional board of incompetents. Our case was useless.

Then the focus needs to be how we mitigate the punishment along the lines of the OP's article. That is do-able. What isn't going to contribute much at this stage is a victim mentality or bandying about claims of corruption when, as it stands, there is no evidence that shows this.

Brent Stephens
31 Posted 28/11/2023 at 16:55:11
Premier League Rule X.4 states:

X.4. In the case of a Disciplinary Dispute, the only grounds for review of a decision of a Commission or Appeal Board by way of arbitration under this Section X shall be that the decision was:
X.4.1. reached outside of the jurisdiction of the body that made the decision;
X.4.2. reached as a result of fraud, malice or bad faith;
X.4.3. reached as a result of procedural errors so great that the rights of the applicant have been clearly and substantially prejudiced;
X.4.4. reached as a result of a perverse interpretation of the law; or
X.4.5. one which could not reasonably have been reached by any Commission or Appeal Board which had applied its mind properly to the facts of the case.

With the appeal not yet heard, we can't prejudge what grounds we might have for arbitration but I guess the Premier League will want to be squeaky clean on the appeal process.


John Keating
32 Posted 28/11/2023 at 17:58:27
We can't prejudge, Brent; however, 4.3 and 4.4 look bloody good!
Graham Fylde
33 Posted 28/11/2023 at 18:18:15
To succeed at appeal, we need to show that the Commission's construction of the elements it considered as persuasive, and that they used in reaching the sentence, are flawed.

The devil is in the detail and I hope we have an army of lawyers on it but I would consider things such as:

The commission agreed with the Premier League on the construction of EFC's overspend being ‘significant.' In discussing overspend, they reason £0 is the target, with interventions starting at £15M. Therefore, EFC's culpability is measured against £124.5M.

That is not what the rules say. If £0 is the target, then why do the rules allow for up to £105M? I would challenge the construction the commission used which would, if incorrect, have contributed to an inappropriate sentence.

The commission states that any overspend confers a sporting advantage. Having stated that the advantage cannot be quantified, it further says that EFC received the sporting advantage for 4 years (due to Covid averaging of 2 seasons).

This construction is not just illogical, it's what lawyers call utter bollocks. In its construction, the commission has applied a notional advantage and increased Everton's culpability to an inappropriate level.

At para 136, the commission stated that the size of the points deduction is to be based on Everton's culpability. In 137 it reasoned that Everton's P&S problems were, with other elements, largely due to purchase of new players.

If Everton can show its nett spend on players decreased in the 3-year period, this can be shown to be factually incorrect and a contributory factor to the commission's inappropriate sentence

When calculating the sentence, the commission opted to be guided by 4 principles–- forwarded by the Premier League. The principles listed are that the penalty should reflect: 1) punishment; 2) vindication of compliant clubs; 3) deterrent; and 4) integrity of the game, noting its worldwide appeal (I think they may have derailed this one by themselves!).

In para 91, it cautions that it ‘recognises that adoption of (the above) should not result in a sanction that is greater than one that is necessary and proportionate for achieving the purpose that underlines the individual heads.'

In using 2) above, the commission is assuming all clubs are compliant with P&S. Elsewhere it states that the Premier League compliance unit relies heavily on what it is told by individual clubs.

Did the commission ask for the current P&S situation of all other 19 clubs? If not, and any is close to or at the limit, its construction of Everton's increased culpability because of its alleged ‘sporting advantage' is inaccurate and has contributed to an inappropriate sentence.

In following the 4 Premier League guidance principles, the commission came to a sentence that is almost identical to the framework the Premier League put forward mid-hearing and was rejected by the Commission. It is not unreasonable to conclude that the commission's independence was therefore compromised (Burnham characterises the framework as an abuse of power) and, consequently, it breached its own guidelines in para 91.

I think Everton's appeal should centre on the recorded construction the commission put on the factors in the case and its patent disregard for its own warning in para 91.

Brent Stephens
34 Posted 28/11/2023 at 18:19:31
I'll go with 4.5, John.

But I think "the law" in 4.4 means the law of the land not Premier League rules?

John Kavanagh
35 Posted 28/11/2023 at 20:30:29
I think through all of this, our legal representation and case was perfectly in sync with our owners and board. Completely inept and useless. I'd feel more confident if it was our supporters conducting the appeal.

Anyway, even if the deduction was cut to 6 points, people need to keep their eye on the killer phase 2 stage of the Premier League's plan – the compensation settlement. This is designed to ensure our bankruptcy and/or trigger the sale of our four best players in January to the Sky 6 at knock down prices.

Let us remember the core pretext for FFP and P&S - they were allegedly brought in to prevent any club going bust through overspending (the real reason was to prevent any other club ever being able to challenge the Sky 6).

So going back to this core principle, how does introducing punishments so as to deliberately bankrupt a club fit in?

I've always maintained that we should take a case to the CAS based on the Premier League operating systematic bias in favour of a few select clubs both on and off the pitch. We might lose the case but the video evidence that could be presented would be both informative, entertaining and a complete embarrassment to the Premier League, its puppet PGMOL, and its 'independent' commissions.

Jerome Shields
36 Posted 29/11/2023 at 09:31:01
Robert #16

That is what exactly happened. Kenwright did think he had a cosy relationship with the Premier League, even pushing forward his personnel assistant Barrett-Baxendale into prominent positions in it.

Everton did work closely with the Premier League throughout, maybe even thinking that this relationship would allow them to fudge certain issues. City knew they were dealing with a nest of vipers from the start and did not.

I even thought they would get away with it, but vested interests and self preservation of the Premier League showed nothing but contempt for them, determined to name them first in the Premier League to be held accountable, much to the shock of Barrett- Baxendale.

Seeing them as weak enough to be able to change the rules midstream to accommodate their vested interest agenda, paralleled with lobbying against Government intervention. Everton did brief their legal team accordingly, showing they're incompetent in running anything.

In the background was the Goose, Moshiri, trying to hold onto the golden egg he had left and which they are now after. They do think he is a goose and every Evertonian knows they are right

I agree that a structured approach is important. Andy Burnham's letter adds to the outcome of what has been structured as a modern media campaign of pressure. The various All Together Now and Fan Advisory Board groups need to adapt a similar framework to what has been stated in this article.

Bobby Mallon
37 Posted 01/12/2023 at 07:09:12
I don't think the club and especially Moshiri – give a flying fuck to be honest.

People on here write we should do this, we should do that but it's only the fans that can keep the pressure on.

I don't think Moshiri cares anymore, he's just waiting to sell up. I hope he royally fucks off and soon.

Dave Waugh
38 Posted 12/12/2023 at 10:56:19
What about the PL's Standard Direction No.8 which requires the PL to raise a PSR breach within 14 days of a club publishing its annual accounts. The PL didn't notify until Day 27 ! Okay, it's a technicality - but it's their rules !

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