It appears that I didn't have a "non-starter" listed behind him in the rest heirarchy. The other 3 players behind him were starts in RF, CF, and SS. I signed an IFA, placed him right behind him in the hierarchy and the sim finally benched him.
I've struggled with figuring that out for about 6 seasons now... glad to know that it actually works, as long as I've got someone there available to play that position.