Team Zero vs. Samcro Reaper Crew – 3 F.J. 177 (October 12, 2011) – fantasy football trade dispute (Brady/A.Johnson/Fitzgerald)

 

SUPREME COURT OF FANTASY JUDGMENT

Team Zero vs. Samcro Reaper Crew

ON PETITION FOR WRIT OF CERTIORARI FROM THE SOFTBALL LEGENDS FANTASY FOOTBALL LEAGUE

Decided October 12, 2011

Cite as 3 F.J. 177 (October 2011)

Factual Background

A fantasy football league called the Softball Legends Fantasy Football League (hereinafter referred to as “SLFFL”) has been in existence for just under a decade and is comprised of twelve (12) teams.  These teams compete against each other on a weekly basis during the National Football League (“NFL”) season using the statistics of professional players as a basis for accumulating points in head-to-head competition with opponents to determine which fantasy team won or lost.  The SLFFL is a non-keeper league hosted on the ESPN fantasy football platform.  The league utilizes ESPN’s standard scoring system, which is 6 points for a rushing or receiving touchdown, 4 points for a passing touchdown, 1 point per 10 yards rushing or receiving, 1 point per 25 yards passing, 2 extra points for touchdowns over 40 yards, and minus 2 points for fumbles lost and interceptions.

The league is not governed by a written Constitution.  However, using ESPN’s standard features, the SLFFL allows league members to vote on trades made between teams.  Historically, the SLFFL has utilized an independent arbitrator to rule on trades that have been vetoed by more than 50% of the league. 

On October 11, 2011, a trade was made between Team Zero and Samcro Reaper Crew which is the subject of this dispute.  Team Zero has agreed to trade Tom Brady (QB-NE), Andre Johnson (WR-HOU), and Felix Jones (RB-DAL) to Samcro Reaper Crew in exchange for Ryan Fitzpatrick (QB-BUF), Tim Hightower (RB-WAS), Beanie Wells (RB-ARZ), Larry Fitzgerald (WR-ARZ), and Robert Meachem (WR-NO).  Several league members vetoed the trade which prompted the SLFFL commissioner to submit the case for review.

Procedural History

On September 27, 2011, these same two teams agreed to the following trade: Team Zero sent Tom Brady (QB-NE) to Samcro Reaper Crew in exchange for Rex Grossman (QB-WAS), Tim Hightower (RB-WAS), and Jeremy Maclin (WR-PHI).  Several league members vetoed the trade arguing that Team Zero did not get sufficient value in return for Brady.  This trade was submitted to the Court for review.  See Team Zero v. Samcro Reaper Crew, 3 F.J. 168 (September 2011) (holding that the trade of Tom Brady in exchange for Rex Grossman, Tim Hightower and Jeremy Maclin should be rejected because the package of players in return for Brady was inequitable and did not comport with the best interests of the league).

The Court advised that the teams should be afforded the opportunity to amend and modify the trade to make it more equitable. 

On September 28, 2011, Team Zero and Samcro Reaper Crew did in fact amend the deal.  Samcro Reaper Crew replaced Grossman with Jay Cutler, thus making the proposed trade Tom Brady for Cutler, Hightower and Maclin.  This trade was also challenged and subsequently submitted to the Court for review.  See Team Zero v. Samcro Reaper Crew, 3 F.J. 172 (September 2011) (holding that the trade of Tom Brady in exchange for Jay Cutler, Tim Hightower and Jeremy Maclin should be rejected because the package of players in return for Brady was inequitable and did not comport with the best interests of the league).

Once again, the Court recommended that the two teams continue working on a deal that is more equitable and fair.  On October 11, 2011, a third trade between the parties was agreed to and is now the subject of this appeal.

Issue Presented

(1)   Should the second amended trade between Team Zero and Samcro Reaper Crew be approved?

Decision

The Supreme Court of Fantasy Judgment typically favors individual fantasy sports participants and teams’ ability to make moves, transactions, and trades.  People pay money to purchase a team in a league and have an expectation of freedom to draft and manage their team accordingly.  See 4 Ponies v. Carson City Cocks, 3 F.J. 13 (May 2011).  Whether success is bred from that individual’s decision-making is purely left to some skill, luck, dedication, and savviness.  The Court also acknowledges that the analysis for evaluating trades is much different in a keeper league than a non-keeper league.  A trade that may look uneven or lopsided on its face may receive a different opinion when it is involved in a keeper league.  In non-keeper leagues, there is no rationale for thinking ahead, nor is there any need to stockpile young, inexpensive talent.  See Smittydogs v. Moneyball, 1 F.J. 32, 33 (June 2010).  Since the SLFFL is a non-keeper league, the analysis of the players involved in the trade will limited to their present day value and projected value through the 2011 season.

The scope of the Court’s authority is to govern and advise when there is a dispute as to the validity of trades, rulings, decisions or other issues that arise within the league.  See Silveramo v. Nation, 2 F.J. 38, 41 (October 2010) (holding that making a judgment on whether an individual did something stupid falls outside of the Court’s jurisdiction).  It is not up to the Court to make a determination on what is considered intelligent.  Unwise decisions should not be scrutinized or vetoed merely because they are unwise.  See Road Runners v. Urban Achievers, 3 F.J. 47, 50 (June 2011) (holding that the main criteria for evaluating a trade is its inherent fairness, not whether it was an intelligent decision by a league member to make the deal).  Rather, the Court’s role in this jurisdiction is to evaluate the objective merits of a deal and ensure that the integrity of the league is maintained.  See Victoria’s Secret v. C-Train, 2 F.J. 32, 35 (October 2010). 

The Court has always held that the approval or rejection of a trade is based purely on its fairness, free from collusion, and in the best interests of the league.  Whether a trade is intelligent or popular will not be part of the analysis.  See 4 Ponies v. Beaver Hunters, 3 F.J. 26, 27 (June 2011).  The virtue of a trade is measured in both quantifiable criteria and subjective needs of the teams involved.  See Carson City Cocks v. Stud Muffins, 3 F.J. 23, 24 (May 2011).

One factor that the Court must always consider is whether there is any collusion or under-the-table dealings going on between teams.  In the prior two cases involving these parties’ trades, the Court was not presented with any evidence of such malfeasance, so assumptions were made that this was not an issue.  However, in the SLFFL’s case submission, there was testimony from the commissioner that “there is starting to be rumblings of collusion between Team Zero and Samcro Reaper Crew.”  The commissioner did not provide any evidence in support of such an allegation.  It has been confirmed by the commissioner that the owners of these two teams are in fact friends to some degree.  The fact that the league members are friends is not demonstrative in and of itself of collusion.  See Jetnuts v. Joker’s Wild, 2 F.J. 15, 16 (September 2010)

When presented with allegations or suspicions of collusion, the Court will look at the evidence in the light most favorable to the accused.  This is because acts of collusion within a fantasy league are one of the most serious fantasy sports crimes that can be committed and can undermine the integrity of a league more so than almost anything else.  There is an unwritten and generally accepted code of conduct for fantasy sports leagues that has existed for decades.  It goes beyond the scope of league constitutions, commissioner service packages or money prizes.  This unwritten code includes the provisio that one will not cheat at fantasy sports.  See Going, Going, Gonzalez v. Fantasy Baseball League, 1 F.J. 29, 30 (May 2010).  Based on the evidence presented, the Court cannot come to the conclusion that there is collusion between Team Zero and Samcro Reaper Crew.  It is apparent that the two teams are motivated to trade with each other.  In all likelihood, they are upset that their fellow league members have vetoed their prior trades.  If this is being used as motivation to further consummate a trade, the Court cannot interfere in such actions.  The question is whether the two teams have some sort of illicit arrangement whereby they will exchange players to better one team’s chances at winning and then share any monetary prizes at the end of the season.  Without any concrete evidence, this conclusion cannot be reached.  However, given the growing concern amongst the other league members, the SLFFL commissioner will need to address this issue with the entire league.

At first glance, the trade of Tom Brady, Andre Johnson, and Felix Jones in exchange for Ryan Fitzpatrick, Tim Hightower, Beanie Wells, Larry Fitzgerald and Robert Meachem still raises red flags because of the presence of elite players such as Brady and Johnson.  Any trade involving premiere fantasy players is going to require additional scrutiny merely because of how valuable they are.  The Court has no issues with the idea of trading superstar players so long as the package in return is equitable and makes sense given the needs of both teams.  See 4 Ponies v. Beaver Hunters, 3 F.J. 26, 29 (June 2011).  The issue to be decided is whether the package of Fitzpatrick, Hightower, Wells, Fitzgerald and Meachem has sufficient value that is equitable to Brady, Johnson and Jones. 

When analyzing the fairness and equity of a trade, the Court will consider each team’s individual needs to assess whether the trade subjectively made sense from each team’s perspective.  See Cajon Crawdads vs. Carson City Cocks, 1 F.J.41, 42 (June 2010) (upholding a trade for Jason Bay because of the Carson City Cocks’ desperate need for a starting outfielder due to the demotion of Cameron Maybin).  This 5 for 3 trade includes a swap of quarterbacks, two running backs for one, and two wide receivers for one.  Team Zero, currently 2-3 and tied for 9th place, would be replacing Brady with Fitzpatrick.  This represents a tremendous downgrade when comparing them to each other.  However, Team Zero also has Cam Newton on his roster so Fitzpatrick would not necessarily be his starting quarterback.  This makes the situation even more tenuous because Brady is being traded for someone who is not necessarily a starter on his team.  Team Zero would be acquiring Hightower and Wells in exchange for Felix Jones.  He also has D’Angelo Williams and Darren Sproles on his roster, so it is questionable whether the newly acquired players would start over his incumbent running backs.  Hightower has already lost playing time in Washington, and his role may be even more diminished due to his failure to disclose an injury to the team, as well as competing with competent running backs Ryan Torain and Roy Helu for carries.  Wells has played well thus far, especially in terms of scoring short yardage touchdowns which has helped inflate his fantasy point total.  However, Jones is arguably better than both Hightower and Wells due to his explosive breakaway speed, the myriad of other offensive weapons on the Cowboys’ roster, and his propensity to catch passes which is significant in a PPR league.  With respect to wide receivers, Team Zero is trading an injured Andre Johnson in exchange for Larry Fitzgerald and Robert Meachem.  This portion of the trade is equitable because of Johnson’s injury status.  He injured his hamstring on October 2 and missed the Week 5 game against Oakland.  He has undergone multiple MRI’s, but the severity of his injury is still unknown.  Texans’ coach Gary Kubiak hasn’t ruled him out of the Week 6 game just yet.  But, his value is certainly diminished because hamstring injuries typically require weeks to heal.  Even if he does play this week, he will not be 100% and will be very susceptible to injuring his hamstring even worse.  Acquiring Fitzgerald and Meachem for a less than 100% Johnson is a fair exchange for Team Zero.  On the other hand, Samcro Reaper Crew, currently 3-2 and tied for 5th place, would be upgrading exponentially at quarterback by getting Brady.  He would also be pairing Felix Jones with Ray Rice at running back.  Acquiring Johnson is a risk, but his upside is obvious.  Given this analysis, the Court can objectively ascertain both teams’ rationale for agreeing to this trade.

The following is a breakdown of each player’s statistics through Week 5 and their respective points using ESPN’s standard scoring system:

Player

Pass Yds

Pass TD’s

Rush Yds

Rush TD’s

Recs.

Rec. Yds

Rec. TD’s

ESPN Points

Tom Brady

1874

14

13

 

 

 

 

116

Andre Johnson

 

 

8

 

25

352

2

45

Felix Jones

 

 

241

1

12

86

0

33

 

 

 

 

 

 

 

 

194

 

 

 

 

 

 

 

 

 

R. Fitzpatrick

1233

10

32

 

 

 

 

80

T. Hightower

 

 

233

1

10

78

1

40

Beanie Wells

 

 

381

6

4

12

0

74

L. Fitzgerald

 

 

 

 

27

427

2

53

R. Meachem

 

 

7

 

22

228

3

39

 

 

 

 

 

 

 

 

286

The analysis for Brady remains the same as it was for the previous cases between the parties.  The only difference is that he is now the #3 overall fantasy scorer according to ESPN’s rankings (Aaron Rodgers and Cam Newton have eclipsed him).  However, it does not diminish the value that Brady has and his ability to score 20+ points per week.  In comparison, Fitzpatrick has played well for the surprising Bills but he can in no way be counted on for such continued production on a weekly basis.  The exchange of Jones for Hightower and Wells looks uneven just based on their current point totals, but that does not fairly represent their true value going forward.  Hightower is expected to see a major decrease in playing time and is one of three viable options at running back in Washington.  The combination of Fitzgerald and Meachem is equitable for Johnson, especially with his injury.  An injury to a player involved in a trade does not automatically devalue that player.  See Team Zero v. Samcro Reaper Crew, 3 F.J. at 171.  When healthy, Johnson is one of the top three fantasy receivers in the league.  Fitzgerald has the ability to match that production, but Arizona’s limited offense and lack of weapons appears to have hindered his ability to produce at the clip he did a few years ago when Kurt Warner was their quarterback.

The issue boils down to whether the #3 overall fantasy player, one of the top wide receivers (albeit currently injured), and a starting running back with big upside is worth an average fantasy quarterback, two middle tier running backs, a star wide receiver and another marginal receiver.  Based on the statistical breakdown of the players’ point totals involved in this trade, Team Zero’s players to be acquired have accumulated 92 more points than the superstar package of Brady, Jones and Johnson.  But that is not indicative in and of itself that the trade is fair and equitable. A player’s value is not necessarily equivalent to the accumulation of several other less valuable players’ statistics.  See Team Sabo v. Nub Vader, 3 F.J. 55, 56 (July 2011). 

Other arguments were made by the complaining teams that Team Zero did not get enough in value for two superstars such as Brady and Johnson.  However, teams are not obligated to shop players around for a more advantageous deal solely to appease skeptical league members.  See Road Runners v. Urban Achievers, 3 F.J. 47, 50 (June 2011).  This is an important distinction to make because fantasy team owners must maintain the right and freedom to manage their team according to their own preferences.  They should not be forced to accommodate other teams in the league and afford them the opportunity to match or exceed a current trade offer.  However, once again, the complaining league members are correct in their assertions that Team Zero did not receive fair or equitable value for Brady and others in this amended deal. 

Based on the foregoing analysis, the Court again rejects the modified proposed trade made between Team Zero and Samcro Reaper Crew.  The Court’s decision is once again made with care because it typically advocates for individual fantasy owners to be able to manage their teams as they desire.  However, the Court must also consider the best interests of the league overall.  Lopsided trades throw off the competitive balance of the league and can create a slippery slope for future deals.  After three failed attempts at making a fair and equitable trade, coupled with speculation over potential collusion between the teams, the Court recommends that the commissioner intervene and explore whether there is any veracity to those allegations. 

IT IS SO ORDERED.

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