Los Pollos Hermanos vs. Little Stumps – 3 F.J. 192 (October 19, 2011) – fantasy football trade dispute (Welker/Tebow)

SUPREME COURT OF FANTASY JUDGMENT

Los Pollos Hermanos vs. Little Stumps 

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

Decided October 19, 2011

Cite as 3 F.J. 192 (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 18, 2011, a trade was made between Los Pollos Hermanos and the Little Stumps which is the subject of this dispute.  Los Pollos Hermanos has agreed to trade Tim Tebow (QB-DEN) and Pierre Garcon (WR-IND) to the Little Stumps in exchange for Wes Welker (WR-NE).  Several league members vetoed the trade which prompted the SLFFL commissioner to submit the case for review.

Procedural History

After the above-referenced trade was agreed to, several league members vetoed the deal on the basis that the Little Stumps did not get fair or equitable for Welker.  Given that more than 50% of the league vetoed the trade, it has been submitted to the Court for independent review.

Issue Presented

(1)   Should the trade between Los Pollos Hermanos and the Little Stumps 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.  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).  The Court has not been presented with any concrete evidence or speculative allegations of such malfeasance, so assumptions will be made that this is not an issue. 

At first glance, the trade of Wes Welker in exchange for Tim Tebow and Pierre Garcon raises red flags because of the presence of Welker, the top fantasy receiver in the league and the seventh highest point scorer overall according to ESPN standard scoring.  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 Tebow and Garcon has sufficient value that is equitable to Welker.

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 2 for 1 trade includes a swap of wide receivers plus a quarterback.  The Little Stumps, currently 2-4 and tied for 10th place, would be replacing Welker with Garcon at wide receiver.  This represents an incredible downgrade at the position.  The Little Stumps only have Hines Ward, Lee Evans and Steve Smith (CAR) as alternatives at wide receiver.  The difference between Welker and Garcon is extreme and cannot be understated.  Welker is the best fantasy receiver in the league thus far, as demonstrated by his statistics and overall points according to ESPN’s standard scoring.  He is the primary option for Tom Brady in New England’s high scoring offense.  He is on pace for record-setting numbers and is averaging almost 20 points per week.  Garcon has been a favorite target of Curtis Painter in Indianapolis, but it is undisputable that the Colts’ offense is nowhere near as formidable without Peyton Manning.  The Colts also have a weak running game, so defenses are able to focus their schemes on the passing game.  At best, Garcon can be considered a WR3 on a fantasy team.  This pales in comparison to Welker and his #1 status.  As a result, this exchange represents an inequitable and unreasonable downgrade at wide receiver for the Little Stumps.    

Given the analysis above, the acquisition of Tim Tebow would have to be valuable enough to offset the drastic difference between Welker and Garcon.  Tebow, the controversial #1 pick by the Denver Broncos in 2010, was just named the new starting quarterback by head coach John Fox.  His prowess is in his ability to run the ball as opposed to throwing downfield and accumulating yardage.  He will also be hampered by a lack of viable offensive options at his disposal with the recent trade of wide receiver Brandon Lloyd to the St. Louis Rams.  His receiving core will consist of Eric Decker, Demaryius Thomas, and Eddie Royal.  These three are hindered by inexperience and health concerns.  There are also serious questions about Tebow’s ability to lead an NFL offense, so his status as the starter is anything but permanent. 

Some complaining members of the SLFFL have indicated that the team owner of the Little Stumps has a personal affinity for the Denver Broncos which has clouded his judgment in trading for Tebow.  This is pure speculation and will not be considered as part of the Court’s analysis.  In addition, the Little Stumps already have Michael Vick at quarterback.  Besides the week when the Eagles have a bye and barring an injury, the Court cannot rationalize any justification for the Little Stumps choosing to start Tebow over Vick.  There has been some testimony provided to the Court that the Little Stumps have allegedly been trying to trade Vick for the past several weeks.  There was also speculation that a deal was in place for Vick at the time the trade for Tebow was consummated.  Whether this is true or not is also irrelevant in the Court’s analysis. 

On the other hand, it is obvious why Los Pollos Hermanos, currently 5-1 and tied for 1st place, would want to acquire Wes Welker.  He could pair up Welker with another dynamic receiver in Greg Jennings.  Jennings is currently the 5th highest scoring wide receiver with 74 points according to ESPN’s standard scoring.  The combination of Welker and Jennings would give Los Pollos Hermanos arguably the SLFFL’s most dominant wide receiver combination.  He still has Ben Roethlisberger and Joe Flacco as his quarterbacks, so he loses absolutely nothing by trading Tebow.  Given this analysis, the Court can clearly ascertain Los Pollos Hermanos’ rationale for agreeing to this trade.  However, the Court cannot come to a similar conclusion with respect to the Little Stumps.

Normally, the Court will engage in a statistical comparison of the players involved in the disputed trade.  Statistics and point totals are not indicative in and of themselves that a 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 Zero v. Samcro Reaper Crew, 3 F.J. 168 (September 2011) (citing Team Sabo v. Nub Vader, 3 F.J. 55, 56 (July 2011)).  The issue boils down to whether the top ranked wide receiver and seventh highest point scorer overall is worth an unknown entity as a backup quarterback along with an average wide receiver.  Looking at this objectively, the trade does not pass the “sniff test” which is required to even engage in the statistical analysis.  This means that no objective analysis could be provided to equate the value and performance of the players involved in this deal.  It would be a waste of judicial economy to do such an analysis because of the gross disparity between the quality of the players.  See Tiger’s Blood v. Hulkamaniacs, 3 F.J. 58, 60 (July 2011). 

The premise of this dispute is that SLFFL league members believe that the Little Stumps did not get enough in value for a superstar like Welker.  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, in this particular case, the complaining league members are correct in their assertions that the Little Stumps did not receive fair or equitable value for Welker.  Not only is Welker’s production and value exponentially greater than either Tebow or Garcon, but the trade in no way makes the Little Stumps even marginally better. 

Based on the foregoing analysis, the Court rejects this trade between Los Pollos Hermanos and the Little Stumps.  The package being traded for Welker is not fair or equitable compensation.  The deal as it is currently comprised is considered lopsided.  Lopsided trades throw off the competitive balance of the league and can create a slippery slope for future deals.  See Team Zero v. Samcro Reaper Crew, 3 F.J. 168, 172 (September 2011).  The teams should be afforded the opportunity to amend and revise the trade in a more equitable fashion.

IT IS SO ORDERED.

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