Ruling Notice: Last Will

Ruling Notices on GoatFormat.com are typically used to announce reversals of prior rulings or to "fill in the blanks" on issues where official documentation remains silent. Today, we will be doing both with the curious case of Last Will.

We address multiple issues surrounding the proper resolution of Last Will. First, we hold that Last Will's so-called "state" uses the Chain. So when it is triggered by a monster being sent from the owner's side of the field to the Graveyard, it will start a new Chain to which the opponent can respond with their own card effects. Second, we hold that Last Will's "state" must be used by its owner, if at all, the first time a monster is sent from the owner's side of the field to the Graveyard. At this time, the player who activated Last Will may elect to activate its effect to Special Summon a monster. If they choose not to do so, the "state" will expire.

These issues have been particularly difficult for the Judge Corps because documentation on the "old" Last Will (pre-TP7 errata in November 2005) is exceedingly rare. Up until now, we have dealt with Last Will on a case-by-case and judge-by-judge basis. Furthermore, Last Will comes with an inordinate amount of historical baggage and Goat Format happens to have taken place during a strange and anomalous window in the card's history during which the original understanding of the card was overturned, then overturned again, all within a few short years. In short, Last Will is all of a judge’s worst nightmares rolled up into a single card.

I. Ruling History

Last Will was among the first cards released in the TCG. At this time, there were very few "official" sources for TCG rulings. A little-known fact is that many local tournaments in North America had been running OCG tournaments for quite some time at this point, so tournament organizers had grown accustomed to resolving disputes through the use of various unofficial channels for OCG rulings. The most reputable among these was Edo’s Yu-Gi-Oh! Page, which served as a sort of Netrep-before-Netrep in the dark ages of the TCG. There, a Hawaiian player by the name of Ed Hrzic maintained a small database of translations of official OCG rulings for TCG cards. At the time, his site had this to say about Last Will:

If played, does not have to be used.
If played, its effect only works for one Monsters destroyed (i.e., it can't be used multiple times).
Can be used to summon high-level Monsters (level 5 or higher), as long as they are not Monsters with a Special Summon requirement.
Can be used after one of your Monsters has gone to the Graveyard from the Field.

Note that Hrzic correctly points out that Last Will’s state could be triggered at this time regardless of the timing of its initial activation. If your monster was destroyed during your own Battle Phase, for example, you could activate Last Will in your Main Phase 2 and Special Summon an appropriate monster from your deck. This was true of the TCG as well as the OCG.  Upper Deck Entertainment (UDE) published the first version of its Specific Card FAQs page prior to the release of Metal Raiders (MRD) in 2002, but it contained very little in the way of Last Will rulings:

Q: What is the significance of "this card is active for one turn only”?
A: This means that "Last Will" is destroyed after activation. However, the effect remains during that turn. You can activate "Last Will" before your monster is sent to the Graveyard. This card is useful against opponent's Trap Cards such as "Mirror Force".

Q: When 1 monster is sent from the field to the Graveyard, can I Special Summon 2 monsters from my Deck by activating 2 "Last Will" cards?
A: Yes, you can.

For the first year or so of the TCG’s lifespan, this was it as far as Last Will rulings were concerned. Anything else was up to the discretion of one’s local judge. Finally, with the release of Labyrinth of Nightmare (LON) in early 2003, Upper Deck distributed a “tournament rulings” document in private. It affirmed prior understandings of Last Will in the TCG and offered little more:

Monster can only be Special Summoned in face-up position. You can Special Summon 1 monster per 1 "Last Will". The effect remains during that turn. You can activate "Last Will" before or after your monster is sent to the Graveyard or even in the case that your monster is not sent to the Graveyard. This effect includes a Tribute Monster for Tribute Summon or "Cannon Soldier"’s effect, etc.

It was not until the end of 2003 that Curtis Schultz issued the following update to Last Will, in line with concurrent updates to Last Will in the OCG:

The card ruling was recently errata’d by Konami of Japan. You must activate “Last Will” before the monster is sent to the Graveyard.

Steve Okegawa confirmed this update in a Pojo thread in early 2004, explaining the timeline of events and the conflict with the old rulings document:

The Last Will ruling has been changed for quite some time now. Kevin (who got the ruling from Konami of Japan) told us the rulings change several months ago, which in turn got added to the UDE Judge List on Yahoo! Groups, which eventually found its way into the Netrep Files. 

Now, although the Netrep Files themselves cannot be considered official, I can tell you for a fact that Last Will must be activated before a monster is sent from the field to your Graveyard. If you really want confirmation that badly (a UDE Netrep's word should be good enough), you can go ahead and e-mail [email protected] about it. 

However, I'd advise against mentioning the very, very outdated Tournament Rulings PDF file. If you do that, I can't be responsible for the ensuing laughter you'll get from them... 

...It should be a given, but anything you see on UDE's FAQ page overrides anything in the old Tournament Rulings file (which was never meant to be available to the public, incidentally).

This ruling was compiled along with a few others in the 3.0 release of Netrep in early 2004. Most of the other Last Will rulings in that release were unremarkable, confirming simple things such as Last Will’s interaction with tokens or control change effects like Change of Heart. At this point, Upper Deck’s official FAQ did not contain an entry for Last Will at all. The unofficial website Faith of the Fallen, maintained at the time by judges in their capacity as judges but not as representatives of Upper Deck, supplemented the Netrep 3.0 rulings with the following statements which would later be used, virtually word-for-word, in Upper Deck’s official FAQs:

You don’t target a monster when you activate or resolve Last Will. Last Will creates a state whereby, the next time during that turn when your monster is sent from your side of the field to your Graveyard, you may Special Summon 1 monster from your Deck using Last Will’s state. Last Will’s state then ends. These states accumulate, so if you activate 2 Last Wills, then the next time during that turn when your monster is sent from your side of the field to your Graveyard, you may Special Summon 2 monsters from your Deck, and the Last Wills’ states then end. You only Special Summon 1 monster for each 1 Last Will. The state will expire at the end of the turn, or when it is used, whichever comes FIRST. So if you Special Summon using Last Will’s state, then the state is gone, and if the end of the turn arrives without using Last Will’s state, then the state is gone. Monsters Summoned with Last Will’s state are Special Summoned in face-up Attack Position or face-up Defense Position. Last Will’s state will be triggered by Tributing for a Tribute Summon, or for Cannon Soldier’s effect, etc. You can use Last Will’s state to Special Summon a Level 5 or higher monster like Labyrinth Wall. You cannot Special Summon a “Special Summon-only” monster. Last Will’s state is only triggered when your OWN monster is sent from YOUR side of the field to YOUR Graveyard. If Last Will’s state is triggered during the Battle Phase by your monster being sent to your Graveyard, you resolve Last Will’s effect at that time (just like Mystic Tomato) and the newly Summoned monster can attack if it is still during the Battle Phase. If Imperial Order is activated after Last Will has resolved, it will not negate Last Will's "state".

Last Will continued to receive virtually no official ruling statements for the remainder of 2004. Netrep 4.0, released in April of that year, consolidated prior rulings as follows:

“Last Will” must be activated before the monster is sent to the Graveyard. 

“Last Will” only applies for the Turn it is played in. 

“Last Will” will only trigger when your monster is sent to your Graveyard.

“Last Will” does not trigger if Tokens are sent to the Graveyard. 

For each “Last Will” played, one monster will be Special Summoned if a monster goes from the field to the Graveyard. 

Monsters sent to the Graveyard in the Battle Phase of a turn “Last Will” has been activated are Special Summoned in that Battle Phase and if in Attack position may attack. 

“Last Will’s” effect can trigger in the End Phase. If a monster that has a Graveyard effect is sent to the Graveyard the same Turn “Last Will” was played, the controlling player may choose the order the effects resolve in.

Finally, in 2005, Upper Deck’s Specific Card FAQs pages were updated with entries for Last Will. As explained above, this update contained no new information, merely restating what had already been unofficially available on Faith of the Fallen. These comprise the bulk of the rulings that have hitherto been available on GoatFormat.com:

You don’t select a monster as a target when you activate or resolve "Last Will". "Last Will" creates a state whereby, the next time during that turn when your monster is sent from your side of the field to your Graveyard, you may Special Summon 1 monster from your Deck using "Last Will’s" state. "Last Will’s" state then ends.

These states accumulate, so if you activate 2 "Last Wills", then the next time during that turn when your monster is sent from your side of the field to your Graveyard, you may Special Summon 2 monsters from your Deck, and the "Last Wills’" states then end.

You only Special Summon 1 monster for each 1 "Last Will".

The state will expire at the end of the turn, or when it is used, whichever comes first. So if you Special Summon using "Last Will’s" state, then the state is gone, and if the end of the turn arrives without using "Last Will’s" state, then the state is gone.

Last Will’s state will trigger by Tributing for a Tribute Summon, or for "Cannon Soldier’s" effect, etc.

You can use "Last Will’s" state to Special Summon a Level 5 or higher monster like "Labyrinth Wall".

You cannot Special Summon a "Special Summon-only" monster. You CAN Special Summon "Toon Mermaid" with "Last Will's" effect, as long as you have "Toon World" on your side of the field.

"Last Will’s" state is only triggered when your OWN monster is sent from YOUR side of the field to YOUR Graveyard.

If "Last Will’s" state is triggered during the Battle Phase by your monster being sent to your Graveyard, you resolve "Last Will’s" effect at that time (just like "Giant Rat") and the newly Summoned monster can attack before Main Phase 2.

If "Imperial Order" is activated after "Last Will" has resolved, it will not negate "Last Will's" state.

You can Special Summon a 1500 ATK monster that will have higher than 1500 ATK after being Summoned, such as a Fiend with 1500 original ATK while "Yami" is on the field and its ATK once Summoned will be 1700.

You can Special Summon "Muka Muka" even if you have 6 cards in your hand and "Muka Muka's" ATK, once Summoned, will be higher than 1500.

As far as Goat Format is concerned, these rulings conclusively establish that Last Will must be activated before a monster is sent from its owner’s side of the field to the Graveyard and not much else. While our adjudication has been inconsistent, we have for the most part ruled that Last Will’s summon does not use the Chain and that it can be used at any point at which its pseudo-trigger is met during the turn it resolves. Both of these rulings were based on later interpretations of the card, officially codified after its Tournament Pack 7 (TP7) errata in November 2005. Schultz clarifies both points in a series of articles on Metagame in June 2006:

Does using Last Will’s effect to special summon a monster use the chain? Well, no, but that doesn’t mean your opponent has no say in the matter. It just means that both players will have to wait until after you have special summoned your monster before any responses can occur.

Last Will has one final trick that you can take advantage of—and you don’t have to use it right away. When you lose a monster to the graveyard, you don’t have to immediately use the card’s effect. It’s possible that you could lose multiple monsters before finally electing to activate Last Will’s effect.

Schultz was, of course, writing about the post-errata incarnation of Last Will, which is predated by Goat Format by a few months. Normally, these materials would not be acceptable evidence for a ruling in Goat Format. We only considered them on the basis of the following passages, which seemed to imply that the only change to Last Will in the TP7 errata was the point regarding activation timing:

The old text of Last Will said, “…is sent to the graveyard…” and the new text says, “…was sent to the graveyard.” In the past, you needed to activate Last Will before losing your monster to your graveyard. Anything that happened before it was activated would not help, so you needed to plan in advance. Last Will’s condition can now be satisfied by an event that happened earlier in the turn, before you even played it. This utility allows you to react to unexpected events in your turn and surprise your opponent.

In a follow-up article, Schultz goes on to "examine how the revised mechanics of Last Will allows the player to make his or her move, sometimes going beyond what he or she could have done under Last Will’s previous mechanics." Of the examples he discusses, he explicitly identifies only these as deviations from the previous mechanics of Last Will:

Justin plays Last Will in his main phase. He then normal summons Exiled Force and uses its effect to destroy his opponent’s monster. Since his Exiled Force went from his side of the field to his graveyard, he has satisfied the conditions of his Last Will and can now special summon Injection Fairy Lily from his deck.

In this case, the previous and revised mechanics for Last Will were again both satisfied, simply because Last Will was played before Justin’s monster, Exiled Force, was sent to the graveyard. How would things be different if Justin had summoned and used Exiled Force’s effect before Last Will was played? Under the previous mechanics, this would mean bad news for Justin, because his Last Will would not be satisfied with a monster sent to his graveyard before its activation. The revised mechanics, on the other hand, would be completely satisfied, allowing Justin to make the play under the game’s current format.

Amy begins her main phase by special summoning Chaos Sorcerer. She decides to retain priority to use its effect, targeting her opponent Jeremy’s Sangan. Jeremy responds with Torrential Tribute. Neither player continues the chain.  

Torrential Tribute resolves and destroys every monster on the field. Jeremy uses his Sangan’s effect to retrieve a monster from his deck. Afterwards, Amy activates Last Will. Since her Chaos Sorcerer was sent from her side of the field to her graveyard, the condition of her Last Will has already been satisfied, so she can use its effect to special summon Cyber Gymnast from her deck.

In this example, Amy didn’t know that her opponent would use Torrential Tribute, but Last Will allowed her to survive it. The previous mechanics for Last Will would have required her to play Last Will in advance, essentially requiring her to guess what would happen. The flexibility of the current, revised mechanics allowed her to use Last Will after losing her monster to Torrential Tribute, so she would not be defenseless.

Generally, we rule solely on the basis of information that would have been available to a judge in 2005. We tend to deviate from this practice when no such sources are available, when we have good reason to believe such sources were outdated and overruled by 2005, or when a future source places a definite date on a ruling reversal. So resolving these two issues requires a deeper dive into the historical record.

II. Using the Chain

Last Will is a rare example of what was once called a “state-based effect” wherein a “state” is produced by its resolution that enables its owner to do something at a later time, generally before the end of the turn in which the card was activated. Today, we would call these “lingering effects.” These effects are typically identified in rulings with phrases like “creates a state whereby.” Such is the case in Last Will's official rulings in the UDE Specific Card FAQs:

Last Will creates a state whereby, the next time during that turn when your monster is sent from your side of the field to your Graveyard, you may Special Summon 1 monster from your Deck using Last Will’s state. Last Will’s state then ends.

Soul Exchange is another example of a “state-based effect,” identified on Faith of the Fallen with similar language:

When you activate Soul Exchange, select 1 of your opponent's monsters... Soul Exchange then creates a state whereby, at some future point during that turn, you can Tribute that monster instead of 1 of your own.

Resolving or “fulfilling” these “states” was typically seen as an action that does not use the chain. After all, Soul Exchange’s “state-based” effect certainly does not start any new chains after the card itself has resolved. Many judges in 2005 labored under the impression that the same was true of Last Will. Oliver Gehrmann takes exactly this position in a January forum post:

The 'state' created by Last Will can be compared with an continuous [sic] effect which is already on the field. 

It doesn't use the chain and will be resolved BEFORE any other effect after the summon can be activated.

John Danker corrects Gehrmann’s interpretation shortly afterwards, citing an explanation by Schultz of the interaction between Last Will and Monster Gate dating back to October 2004:

The effect of "Monster Gate" Tributes the monster as a cost. 

At this time, the "Last Will" wants to activate, but its effect will need to start a new chain, so it will wait until "Monster Gate" has resolved before it will activate. 

So you would resolve "Monster Gate," and then immediately afterwards you will activate "Last Will's" effect of Special Summoning a monster. 

This is similar to offering "Sangan" as the monster Tributed for "Monster Gate's" cost. "Sangan's" effect will need to start a new chain, so it waits until the current chain with "Monster Gate" finishes resolving.

That's not all. Schultz’s interpretation there is corroborated by a few Netrep rulings posted around the same time. His answer in January 2004 regarding the following interaction with Witch of the Black Forest is particularly notable, painting a picture wherein Last Will's trigger and the Witch's effect are treated as a simultaneous effects:

Q: If “Last Will” has been activated and “Witch of the Black Forest” is destroyed and sent to the Graveyard, which effect will resolve first?

A: The turn player would decide in what order the effects would resolve. They can either Special Summon for "Last Will" first or search for their monster with "Witch of the Black Forest" first. The choice is up to the turn player.

The same principle was extended into the later 4.0 release of Netrep, this time stated more broadly and with a more refined understanding of SEGOC rules:

If a monster that has a Graveyard effect is sent to the Graveyard the same Turn “Last Will” was played, the controlling player may choose the order the effects resolve in.

Recall that the same logic was present in Last Will's entry in the Specific Card FAQs, which would be published some time after Gehrmann's thread. Note here the implication not only that Last Will can be triggered at the same time as the effect of Giant Rat, but also that it can be activated and resolved during the Damage Step, "just like Giant Rat":

If "Last Will’s" state is triggered during the Battle Phase by your monster being sent to your Graveyard, you resolve "Last Will’s" effect at that time (just like "Giant Rat") and the newly Summoned monster can attack before Main Phase 2.

Similar language is found in this entry under Banisher of the Light, again with the word "trigger" and listing Last Will among effects like Sangan and Mystic Tomato:

Effects that trigger when cards are sent to the Graveyard, such as "Sangan", "Witch of the Black Forest", "Mystic Tomato", "The Immortal of Thunder" and "Last Will", will not activate.

Back in the January thread, another poster responds to Danker with confusion, pointing to a later Judge List ruling given by Steve Okegawa:

"Monster Gate's" effect resolves first, and then the state created by "Last Will" resolves. This means that you first pick up cards from the top of your deck to Special Summon via "Monster Gate's" effect, and then you can search your deck for a monster with an ATK of 1500 or less and Special Summon it to the field, since you have fulfilled the state created by "Last Will."

The confusion arises out of Okegawa’s omission of words like “activate” and “start a new chain” in favor of terms like “resolve.” But the poster is quickly corrected by Gehrmann and others, who accept the Schultz ruling as dispositive and decline to read the Okegawa ruling as contradictory. When similar questions arise in later threads, the notable judges present continue to give the same answer established in the January thread. Here, Andrew Roth answers a question about the interaction between Last Will, Rescue Cat and Torrential Tribute in a thread in March:

When the 2 3 Hump Lacoodas hit the field the timing window opens up for a) the turn player to get the 3rd one for Last Will and b) for the opponent to activate Torrential Tribute. So, if both players use their effects, TT will go off before the 3rd one hits the field.   

We need not concern ourselves with whether or not Danker, Gehrmann and Roth are actually correct in their shared interpretation of the words of Schultz and Okegawa. When assigning weight to interpretations of rulings given by notable judges in informal public statements and answers, we begin our inquiry by looking for an official and timely statement by Upper Deck to the contrary. If such a statement can be found, we will only defer to the judge if the historical record supports a conclusion that the judge’s interpretation constituted an established practice at premier events at that time, in contradiction with the official statements of Upper Deck. But on issues where Upper Deck had remained silent in 2005, we are typically content to defer to the judge’s interpretation, provided it is not wholly unreasonable.

We last applied this rule in our notice regarding Gearfried the Iron Knight, where we held that Gearfried’s effect was Continuous. There, we deferred to the informal interpretations of Simon Key, Glenn Cheng and others and overruled an official ruling in the UDE Specific Card FAQs because the historical record supported a finding that “the UDE ruling in question was inconsistently applied or not applied at all at premier events at that time.” Here, we reach the same result for different reasons. As far as we can tell, Upper Deck made no official statements regarding this aspect of Last Will throughout Goat Format, and indeed not until the TP7 errata several months afterwards. So we are content to rule with Danker, Gehrmann and Roth that Last Will's so-called "state" uses the Chain. When it is triggered by a monster being sent from the owner's side of the field to the Graveyard, it will start a new Chain to which the opponent can respond with their own card effects. If it is triggered by the Tribute Summon of a monster with a Trigger Effect like Zaborg the Thunder Monarch, the effects of Last Will and Zaborg will simultaneously trigger and be placed on the same chain. And if it is triggered by a monster's destruction by battle, it will activate during the Damage Step, at the same time as cards like Giant Rat and Sangan.

III. When to Activate

In most respects, Last Will’s effect is treated like an optional Trigger-like effect that cannot miss the timing (i.e. an “if” instead of a “when”). If you Tribute Summon a monster by Tributing a monster you own and control, for example, you can happily activate Last Will’s effect in response to that successful summon, provided Last Will itself has already resolved earlier in the turn. But what if you wanted to wait until later in the turn, such as when that Tribute Summoned monster is destroyed by a Sakuretsu Armor in the Battle Phase? The official rulings provide conflicting evidence:

You don’t select a monster as a target when you activate or resolve "Last Will". "Last Will" creates a state whereby, the next time during that turn when your monster is sent from your side of the field to your Graveyard, you may Special Summon 1 monster from your Deck using "Last Will’s" state. "Last Will’s" state then ends.

If we read the phrase “the next time” maximally, we are led to the conclusion that Last Will can be triggered either the first time after its resolution that a monster is sent from its owner’s side of the field to the Graveyard, or not at all. But the same batch of rulings also tells us that:

The state will expire at the end of the turn, or when it is used, whichever comes first. So if you Special Summon using "Last Will’s" state, then the state is gone, and if the end of the turn arrives without using "Last Will’s" state, then the state is gone.

This ruling appears to list the ways in which Last Will’s “state” can “expire.” Curiously absent is any mention of a player choosing not to “use” the “state” when triggered. As we stated in our notice regarding Mind Crush, the inclusion of one thing is the exclusion of another. When a ruling includes a list of things, it is rarely prudent to assume that the author simply forgot to include further valid items in the list. 

So which interpretation is correct? In the same thread from earlier, Danker and others shared the same confusion. On or around January 20, Ian Estrin of Upper Deck responded to Danker’s question as follows:

You cannot choose when to activate the state based effect, as it will trigger automatically the next time a monster is sent to the Graveyard. 

Since Last Will is an optional effect, its controller can choose to not Special Summon a monster, but the state based effect will not reset. Once its condition has been met, that is the only chance you will have that turn to Special Summon a monster.

Straight from the horse's mouth! After the initial activation and resolution of Last Will, its "state" must be used by its owner, if at all, the first time a monster is sent from the owner's side of the field to the Graveyard. At this time, the player who activated Last Will may elect to activate its effect to Special Summon a monster. If they choose not to do so, the "state" will expire.

These rulings will be enforced at all official GoatFormat.com events, effective immediately. Our Individual Card Rulings will be updated shortly to reflect our new understanding of Last Will. At this time, we decline to answer any further ambiguities that may exist regarding Last Will. For any such questions, contact the Head Judge for your next event.