Steelers vs. Patriots – 3 F.J. 218 (November 19, 2011) – fantasy football trade dispute (Gronkowski/C.Johnson/Colston)

SUPREME COURT OF FANTASY JUDGMENT

Steelers vs. Patriots

ON PETITION FOR WRIT OF CERTIORARI FROM

THE SOUTHEASTERN COACHES ALLIANCE FANTASY FOOTBALL LEAGUE

Decided November 19, 2011

Cite as 3 F.J. 218 (November 2011)

Factual Background

A fantasy football league called the Southeastern Coaches Alliance Fantasy Football League (hereinafter referred to as “SECA”) has been in existence since 2000 and is comprised of fourteen (14) 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 SECA is a non-keeper league hosted on the CBS Sports fantasy football platform.  The league utilizes a customized scoring system which includes points per reception (“PPR”) and various yardage bonuses for touchdown and accumulations. 

The league is governed by a written constitution.  Under the rules of the league, the commissioner has the authority to approve or reject trades made between teams.  The criteria and guidelines for making trades is codified in the constitution as follows:

  1. No collusion.
  2. No trading of the same player or players back and forth between the same coaches in a season.
  3. All trades must benefit both coaches involved.
  4. All trades must be approved before 11:59 pm ET on Saturday nights.

On November 10, 2011, a trade was agreed to between the Steelers and the Patriots. The Steelers agreed to trade Chris Johnson (RB-TEN) and Percy Harvin (WR-MIN) to the Patriots in exchange for Rob Gronkowski (TE-NE), Marques Colston (WR-NO), and Mike Tolbert (RB-SD).  This trade is the subject of the dispute submitted to the Court.

Because the trade at issue in this case was consummated before Week 10 of the NFL season, the Court will only consider facts and statistics as of the date of the trade.  This means that game results, statistics, and injuries sustained during Week 10 will not be considered in the Court’s analysis. 

Procedural History

After the above-referenced trade was agreed to, the SECA commissioner rejected based on the fact that the trade did not benefit the Patriots pursuant to Rule #3.  Coach Askew, the owner of the Patriots, argued that the trade did benefit his team.  However, the commissioner disagreed and invoked Rule #3 to affirm his decision to reject the proposed trade.  The commissioner, in turn, suggested that the teams restructure the trade in a more equitable fashion and resubmit it for approval.

On November 11, 2011, the Steelers and Patriots agreed to a revised trade.  The Steelers agreed to include Matt Schaub (QB-HOU) with his package of Chris Johnson and Percy Harvin in exchange for Rob Gronkowski, Marques Colston, and Mike Tolbert.  The commissioner approved this trade based on the fact it benefited the Patriots because Schaub represented an upgrade over the quarterbacks he had on his team at the time.

On November 13, 2011, Schaub sustained an injury during the Houston Texans game and will likely miss the remainder of the season.  This essentially means that the net result is the original trade that was rejected by the commissioner.

Coach Askew of the Patriots still challenges the commissioner’s rejection of the initial trade.  The commissioner has submitted this case to the Court seeking a decision on whether the original trade between the Patriots and Steelers should have been rejected.

Issue Presented

(1)   Should the commissioner’s rejection of the original trade between the Steelers and the Patriots be upheld?

Decision

Before the Court begins its analysis, it must first confirm that the appellant has standing to bring such a dispute.  The initial trade was rejected and subsequently modified.  Upon the restructuring of the trade, it was approved.  Now, the appellant seeks judicial intervention after one trade was rejected and another one was approved.  The timing of these trades and the appeal being filed is irrelevant to whether a party may submit a case to the Court.  There is no statute of limitations on when an issue can be brought to this Court for review.   See Bald Eagles v. Weasel D, 3 F.J. 205, 209 (November 2011).

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 is unknown what the relationship, if any, is between Coach Askew of the Patriots and Coach Powers of the Steelers.  See Jetnuts v. Joker’s Wild, 2 F.J. 15, 16 (September 2010) (holding that the relationship between two league members is not demonstrative in and of itself of collusion).  However, the Court has not been presented with any testimony or evidence of suspected collusion between the Patriots and Steelers.  As such, it shall be presumed that collusion is not at issue.    

At first glance, the trade of Chris Johnson and Percy Harvin in exchange for Rob Gronkowski, Marques Colston, and Mike Tolbert raises some red flags.  One of the reasons for this is because Johnson has been such a disappointment despite his high ADP (average draft position).  Fantasy teams that drafted Johnson as a 1st round pick have been greatly disappointed with his lack of production, especially compared to the last few years.  His holdout during training camp, coupled with the accumulation of physical damage to his body over the years has had detrimental effects on his performance.  Further, Gronkowski is arguably the most productive tight end in both real and fantasy football.  He has become one of Tom Brady’s favorite and most reliable targets in New England’s pass-happy offense.  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 a devalued Johnson and Harvin is sufficiently equitable to Gronkowski, Colston and Tolbert.

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 3 trade includes a swap of running backs and wide receivers, plus a tight end going to the Steelers.  The Steelers would be acquiring Gronkowski which represents a tremendous upgrade at the position.  They already have Jimmy Graham (NO), Ben Watson (CLE), and Joel Dreesen (HOU).  Graham has had a great season and could form a dynamic 1-2 punch at tight end that is practically unmatchable by any other combination of tight ends (it should be noted that the SECA permits teams to start as many as three tight ends in weekly lineups).  With respect to the even swap of wide receivers, the trade unquestionably favors the Steelers.  Marques Colston is the Saints’ number one wide receiver and one of Drew Brees’ most frequent targets.  Colston is not having his best statistical season thus far, but his numbers, performance, and projections are all significantly better than Harvin.  Another thing to consider is the fact that the Minnesota Vikings have given rookie Christian Ponder the starting quarterback job.  He is essentially learning the position and getting used to the NFL right now, so the Vikings are not likely going to be scoring many points through the air.  Plus, Harvin is their best wide receiver so defenses will put their best coverage defensive back on him and focus their attention on stopping Adrian Peterson and the Minnesota running game.  On the other hand, Colston is featured in New Orleans’ high scoring and talented offense led by Brees.  Finally, the even swap of running backs is more even and may swing in the Patriots’ favor.  However, this is merely because of the potential that Chris Johnson possesses.  He has had a terrible year, but he is always capable of breaking out and putting up elite fantasy numbers on any given week.  Mike Tolbert has been banged up all year and splits his carries with Ryan Mathews.  This diminishes his value because he is not the featured back.  Based on the foregoing, the Court sees how this trade benefits the Steelers with the upgrades at tight end and wide receiver.

On the other hand, the Court is struggling with how to conceive of any way that this trade benefits the Patriots.  They are trading away Gronkowski and his 152 fantasy points leaving them only with Brandon Pettigrew at tight end.  Pettigrew has had a nice season on a resurgent Detroit Lions’ team, but he is a significant downgrade at the position.  In addition, they are taking a hit at wide receiver by getting Harvin for Colston.  The one area that makes this trade at least enticing for the Patriots is getting Chris Johnson and pairing him with Arian Foster.  This has the potential to be a deadly combination, but that pipe dream is far from a reality with the way Johnson had a played all year and the fact Foster has been injured and is seeing some of his carries being given to Ben Tate.  However, the Johnson/Foster combination is merely potential.  Looking strictly at his numbers before Week 10, Johnson only had 366 yards with one touchdown.  In fact, Tolbert had outscored Johnson by 22 points heading into Week 10.  That doesn’t necessarily mean he is better – it just puts things in perspective when comparing the qualities and attributes of players, as well as the fairness and equitability in a trade.

Based on this analysis, the Court confirms that the Steelers will benefit greatly from this trade.  On the contrary, the Court cannot conclude that the Patriots will receive any benefit whatsoever from the trade as configured.  Adding up all of the players’ CBS fantasy points and averages, it turns out that the Patriots would be giving up 191 points (27 points/week) as a result of the difference in players’ points. 

While points are only part of the equation when determining the fairness and equitability of a trade, a difference of 191 points is too significant to overlook.  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 is whether both teams benefited pursuant to the rules delineated in the constitution to approve or reject a trade.  It is apparent the Patriots do not benefit from a points perspective.  Additionally, they sustained major downgrades at more than one position which does not indicate any benefit from a roster or personnel standpoint.  Based on this, the Court concludes that no benefit would be gained by the Patriots in making this trade. 

The premise of this dispute is that the SECA commissioner believed the Patriots did not get enough value in the proposed trade to satisfy the language of the rules which requires a trade to benefit both teams in order to be approved.  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 case, the commissioner was correct in his assessment that the disparity between what the two teams benefit by making this trade is too vast to justify approving the trade in good faith.

In conclusion, the Court upholds the commissioner’s rejection of this proposed trade.  When a league constitution grants the commissioner the authority to review trades based on delineated criteria, he has the discretion to reject a trade if he determines it is unfair.  See Tiger’s Blood v. Hulkamaniacs, 3 F.J. 58, 62 (July 2011).  The package offered to the Patriots does not benefit them in any justifiable way.  A trade will be rejected when the Court cannot objectively ascertain any benefit to one of the teams and the net result doesn’t makes a team better now or in the future.  See Los Pollos Hermanos v. Little Stumps, 3 F.J. 192, 195 (October 2011).  The league rules also require that all trades benefit both teams involved.  Players’ quantifiable statistics and NFL teams’ pragmatic team philosophies and outlook enable the Court to objectively determine that this trade should not be approved.  The deal as it was comprised was considered lopsided, which could potentially 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. at 172.  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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