I think this is exactly the wrong distinction and perhaps explains a lot of the talking past each other that's gone on in this thread.I have the impression that most of the sandbox-type DMs here are non-fudgers when it comes to the dice. After all, fudging the dice to determine what happens invalidates the point of allow the players to make choices.
I also have the impression that most of the "There's no difference" folks here are fudgers when it comes to the dice. After all, not fudging the dice to determine what happens invalidates the way they planned the encounters to go.
And that is, perhaps, a good encapsulation of the difference: Whose choices does the DM empower? His, or his players'?
I'm a non-fudger (it's a game, the dice fall where they may) and I run what I would call a sandbox style game (the players have a wide array of choices and player initiative is a valued part of determining what those choices are) but I don't spend time developing "choices" that I know won't see play because the players will immediately recognize that the choice is suboptimal and I also don't make any bones about acknowledging that when it comes to making choices about the setting, my first priority is facilitating encounters and events that will be meaningful and fun for the players (which, in most cases, means the challenge is level appropriate, even if all the NPCs and monsters involved in the encounter aren't).
The distinction isn't fudging vs. non-fudging or sandbox vs. set-piece, it's prioritizing the development of play-relevant material vs. prioritizing the development of setting relevant material which may or may not impact actual play.
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