Tiger’s Blood vs. Hulkamaniacs – 3 F.J. 58 (July 6, 2011) – Fantasy Baseball Collusion

SUPREME COURT OF FANTASY JUDGMENT 

Tiger’s Blood vs. Hulkamaniacs

ON PETITION FOR WRIT OF CERTIORARI FROM THE CALIFORNIA PENAL FANTASY BASEBALL LEAGUE 

Decided July 6, 2011

Cite as 3 F.J. 58 (July 2011)

Factual Background

A rotisserie fantasy baseball league named the California Penal Fantasy Baseball League (hereinafter referred to as “CPFBL”) utilized an auction-style draft hosted on Yahoo’s fantasy baseball commissioner platform.  The CPFBL is a 12-team rotisserie league using both AL and NL players with each team allowed to keep up to five players for a maximum of three seasons.  Like many rotisserie leagues, the CPFBL is a 5×5 league using the standard hitting and pitching categories (AVG, HR, RBI, Runs, SB, W, ERA, K’s, SV, WHIP).  Statistics are cumulative throughout the season and each team will accrue points based on their standings for each individual scoring category.  Each team has a budget of $260 to draft 25 players and then $100 to purchase free agents after the draft has concluded.

The rules and guidelines of the league are delineated in a written document called the “CPFBL Constitution.”  Contained within the CPFBL Constitution is a section entitled “Trading and Transactions” which is marked as Article III.  Under Article III is a provision III.A entitled “Trades Between Teams” which includes the following pertinent sub-provisions:

2.   Teams shall be permitted to trade players at any time during the course of the season up until the trading deadline which is set for September 1, 2011.

4.   Teams shall not be permitted to trade draft picks or any other intangible asset.

5.   Trades made between teams must be of fair value and free from collusion.

6.   The objective criteria used to measure the fairness of a trade includes the statistics of each player involved, the needs of each team at the time the trade is made, the contract status of each player, and the projected value for future seasons.

7.   Collusion, including allegations of collusion, shall mean any written and/or verbal communications, or pattern of behavior, whereby two or more teams conspire to exchange players in return for shared future financial gain or other intangible benefit.

8.   The CPFBL Commissioner shall have sole authority to approve or reject all trades proposed and entered into.

Procedural History

Two teams in the CPFBL – Tiger’s Blood and the Hulkamaniacs – attempted to make a trade that has been rejected by the league’s Commissioner.  Tiger’s Blood, in last place, offered Matt Holliday (OF-STL), C.C. Sabathia (SP-NYY), Anibal Sanchez (SP-FLA) and Robinson Cano (2B-NYY) to the second place Hulkamaniacs in exchange for Hiroki Kuroda (SP-LAD), Mike Carp (1B-SEA), Matt Joyce (OF-TB), Garrett Jones (1B-PIT), Jamey Carroll (SS-LAD), Jonathan Sanchez (SP-SF), and Mark Ellis (2B-COL).  The trade was offered through Yahoo’s internal trade offer process and was subsequently accepted by the Hulkamaniacs.  Upon accepting the trade, it went to the Commissioner for approval.  The Commissioner rejected this trade on the basis that the trade was unfair and upon suspicion of collusion between the two teams. 

The Hulkamaniacs immediately challenged the Commissioner’s rejection of the trade.  The Commissioner explained that the trade failed to meet the objective criteria as outlined in the league’s Constitution.  Additionally, the Commissioner cited several examples of his suspicion that Tiger’s Blood was trying to sell off his players and was not interested in further competing in the league.  The Commissioner further cited the personal relationship between the team owners as augmenting the cause for suspicion, which was corroborated by other league members who have previously questioned the motives of Tiger’s Blood.

Some of the examples cited by the Commissioner regarding Tiger’s Blood actions include his failure to properly input a complete starting lineup in four previous weeks, failing to replace injured players when they are placed on the disabled list, and failure to respond to trade offers from teams other than the Hulkamaniacs.

The Hulkamaniacs and Tiger’s Blood have challenged the Commissioner’s decision to reject the proposed trade and argue that the Commissioner has abused his power and discretion.

Issue Presented

(1)   Should the trade between Tiger’s Blood and the Hulkamaniacs be approved or rejected?

Decision

The Supreme Court of Fantasy Judgment typically favors individual fantasy sports participants and teams’ ability to make moves, transactions, and trades.  The standard of review has been that people pay money to purchase a team in a league, draft their team, and manage it accordingly.  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.  The reasons for this are obvious, but must be restated.  In a keeper league, teams that are having unsuccessful seasons are more likely to continue to pay attention and make moves that will set themselves up for better success in the following season.  They can do this by acquiring young talent that is not under contract within the league, or by dumping salary (assuming it is an auction league) and allowing greater financial flexibility to sign key players in the next season’s draft.  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).

At first glance, the trade of Matt Holliday, C.C. Sabathia, Anibal Sanchez and Robinson Cano in exchange for Hiroki Kuroda, Mike Carp, Matt Joyce, Garrett Jones, Jamey Carroll, Jonathan Sanchez, and Mark Ellis looks completely unfair and inequitable.  No objective analysis could be provided to equate the value and performance of the players involved in this deal.  Typically, the Court will provide a statistical comparison of players being traded to illustrate the difference or similarities of the players involved.  However, this is a rare case where there is no need to even do that because of the gross disparity between the quality of the players.  As such, the Court’s affirmatively holds that this trade does not pass muster in doing its initial “sniff test.”

The fact that players of Holliday, Sabathia and Cano’s caliber are being traded does not raise suspicion in and of itself.  There are no issues with trading such high profile stars 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).  However, when several high quality stars are dealt in a package that does not net anything nearing the same quality or projected value in return, it raises several inherent red flags.  One of the flags being raised is the futile attempt to package several players together to try and match the value of Holliday, Sabathia, A. Sanchez and Cano.  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).  Even if the seven players offered by the Hulkamaniacs could accumulate statistics that are equivalent to Holliday, Sabathia, A. Sanchez and Cano, it does not mean the value being exchanged is similar or equivalent.

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. at 27.  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).  The Court must always consider whether there is any collusion or under-the-table dealings going on between teams.  The CPFBL Commissioner has made allegations of such malfeasance, which is compelling in conjunction with the inequity of the trade itself.  Such allegations are taken very seriously and must be scrutinized very closely by the Court. 

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).  Much like the standard of review in Motions for Summary Judgment, the facts of the case must be viewed in the light most favorable to the party being accused of collusion.  Teams that pay to participate in fantasy leagues should be given the freedom to manage their teams accordingly.  See 4 Ponies v. Carson City Cocks, 3 F.J. 13 (May 2011).  The mere fact that a league owner fails to make appropriate changes to his lineup or roster to compensate for injuries does not necessarily correlate with abandonment of his team or collusive intent in and of itself.  It may demonstrate laziness or lack of care, but there has not been sufficient evidence to prove abandonment.  See Miguel’s Mashers v. Detroit’s Finest, 3 F.J. 19, 21 (May 2011).  Here, while it is unfortunate that Tiger’s Blood has inexplicably elected not to effectively manage his team, the fact remains that he paid for the ability to do what he pleases with his team, even at his own detriment.  Additionally, the fact that the league members are close friends is not conclusively demonstrative of collusion.  See Jetnuts v. Joker’s Wild, 2 F.J. 15, 16 (September 2010) (holding that family members should not be held under any additional scrutiny when making trades outside of evidence supporting a collusive effort).  Having reviewed the facts and testimony presented while giving Tiger’s Blood the benefit of the doubt, the Court is not convinced that this trade was made in good faith.

When looking at the totality of the circumstances and the nature of the trade being made, the evidence does show that, more likely than not, there was malicious intent that rises to the level of collusion.  Outside of written proof or verbal confirmation, there is no way to definitely prove the existence of such conduct.  Regardless, the Court can draw inferences from the evidence presented and the circumstances surrounding the proposed trade whether collusive conduct is present.  Tiger’s Blood appeared to stop showing interest in managing his team based on the repeated failures to set a correct and complete lineup.  He made no effort to amend his lineup or roster to replace players that were inactive due to being placed on the disabled list.  He refused to respond in any fashion to trade proposals made by other teams.  He has a close, personal relationship with the owner of the Hulkamaniacs (as discussed previously, this in and of itself is not indicative of malevolent conduct).  Finally, the trade itself is so grossly uneven that no rational basis for entering into the deal can be deciphered.  Taking all of these factors into consideration collectively, the Court holds that collusive conduct did in fact exist in this particular trade. 

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).  Given the players involved in this trade and the substantial differential between the values of each package, the Court cannot find any benefit to be gained by Tiger’s Blood entering into this exchange.  While Tiger’s Blood would be gaining players at comparable positions plus additional players to add to his bench, the quality of such players pales in comparison to what he is trading away.  As such, there is no rational basis as to why Tiger’s Blood would agree to such a trade but for some ulterior motive that is potentially detrimental to his own team and the integrity of the league.

The dichotomy between teams’ motivations is precisely why the Court must look at trades in keeper leagues differently than non-keeper leagues.  See Smittydogs v. Moneyball, 1 F.J. at 34.  In terms of keeper league status, Sabathia and Cano are in their final year under contract before returning to the free agent pool.  Holliday and A. Sanchez both have one year remaining under contract.  While it is common for teams out of playoff contention in keeper leagues to trade expiring contracts for talent that will provide long-term production, this is simply not the case here given the quality of the players Tiger’s Blood would be receiving in return.  The package of Kuroda, Carp, Joyce, Ellis, Carroll, J. Sanchez and Jones simply does not offer much in terms of present or future value.  If this trade had been proposed in a non-keeper league, the Court would vehemently reject it as well. 

The CPFBL Commissioner was well within his rights according to the league Constitution to evaluate the trade based on the delineated criteria and subsequently reject the trade using his discretion and authority.  The Court is a strong advocate for having written Constitutions that govern fantasy sports leagues because “all league members are aware of the rules and guidelines in place, and it shifts the burden onto the league members to read, understand, and adhere to the rules that are delineated.”  See Shawn Kemp is My Daddy v. Fantasy Basketball League Commissioner, 2 F.J. 24, 25 (October 2010).  Here, there was clear language in the Constitution laying out what criteria trades should be evaluated with.  Additionally, the Commissioner is granted sole authority to approve or reject trades using the aforementioned criteria because lopsided trades throw off the competitive balance of the league and create a dangerous slippery slope for future trades.  See 4 Ponies v. Beaver Hunters, 3 F.J. at 29.

Based on the aforementioned reasons, the CPFBL Commissioner properly rejected this trade between Tiger’s Blood and the Hulkamaniacs.  This decision was made in accordance with the powers granted to him in the league Constitution, as well as being in the best interests of the league overall.  The Commissioner must make decisions that uphold the integrity of the league, and rejecting such a trade that is likely ripe with collusion and inequity does exactly that.  The Court hereby upholds the Commissioner’s decision and rules that the subject trade should be rejected as it is in direct violation and contradiction of the league’s explicit rules.

IT IS SO ORDERED.

facebooktwittergoogle_plusredditpinterestlinkedinmailby feather