Road Runners vs. Urban Achievers – 3 F.J. 92 (July 29, 2011) – fantasy baseball trade collusion (Pujols, Halladay, Lincecum, Beltran)

SUPREME COURT OF FANTASY JUDGMENT

Road Runners vs. Urban Achievers

ON PETITION FOR WRIT OF CERTIORARI FROM THE ANGERTHAL LEAGUE

Decided July 29, 2011

Cite as 3 F.J. 92 (July 2011)

Factual Background

A rotisserie fantasy baseball league (hereinafter referred to as “Roto league” or “The Angerthal League”) that was formed in 1988 and utilized an auction-style draft seeks an evaluation of a trade made between two teams within the Roto league.  This is a twelve-team NL-only keeper league where each team has a $260.00 salary cap to draft 23 players.  During the season, there is no limitation on players’ salaries.  Teams are permitted to retain between 7-15 players during each off-season with each individual player allowed to be kept for three years before they must either be signed to a long-term contract (“LTC”), play, or be returned to the free agent pool. 

Players with a LTC have a progressive salary structure of (Base Salary + ((N-1) * 5)) where N = the number of years a team wants to sign the player. Once a player is signed to a LTC, there is a real monetary penalty (which depends on the structure of the salary of the player – if the salary is less than $10, then there is a penalty of $20; or there is a penalty of two times the player’s salary if he is released early from a LTC). All money collected for penalties is placed into the pool for prize money.  After a LTC is completed, the player is not eligible to be signed again and must be placed back into the free agent pool for the next season’s draft. Teams that finish in 1st through 4th place in the Roto League will win money prizes at the end of each season.   

As with many rotisserie leagues, the Angerthal League uses the standard 5×5 scoring categories to determine the standings and prize money.  For offensive players, the five categories are: (1) batting average; (2) homeruns; (3) runs batted in; (4) runs scored; and (5) stolen bases.  For pitchers, the five categories are: (1) wins; (2) earned run average; (3) WHIP (walks+hits/innings pitched); (4) strikeouts; and (5) saves.  Statistics are cumulative throughout the course of the season and there are no head to head games contained within the Roto league.

Procedural History

The Road Runners have made a trade with the Urban Achievers.  The Road Runners traded Tim Lincecum (SP-SF), Chris Coghlan (OF-FLA), and Brett Wallace (1B-HOU) to the Urban Achievers in exchange for Carlos Beltran (OF-SF), Roy Halladay (SP-PHI) and Albert Pujols (1B-STL).

According to the Angerthal League’s Commissioner, at least four other members of the league have vehemently challenged this trade alleging there is a significant disparity in the value of the players exchanged.  The Commissioner expressed concern over the integrity of the subject trade based on how incited the league opposition was to the trade. 

These same two teams were involved in a prior dispute cited as Road Runners v. Urban Achievers, 3 F.J. 47 (June 2011) where the trade of Jason Motte (RP-STL) in exchange for Antonio Bastardo (RP-PHI) was challenged and accusations were made that perhaps one team was helping a friend out by dealing a closer (Bastardo, at the time) for a middle reliever.  For the reasons set forth in that opinion, the Court approved the trade.

Issue Presented

(1)   Should the trade between the Road Runners and Urban Achievers be upheld and approved?

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).

Another factor that the Court must always consider is whether there is any collusion or under-the-table dealings going on between teams.  In the previous cases between these two teams, the league Commissioner established that the two members involved in the trade are very close friends.  Back in June 2011, no other league members outwardly accused the Road Runners and Urban Achievers of collusion.  However, there was a general consensus that the Bastardo-Motte trade was an instance of one friend helping another.  Now just over a month later, the Court is presented with another disputed trade between these same teams who happen to be in the same position in the standings as they were back then – the Road Runners are in 1st place and the Urban Achievers are in 11th place.  Once again, the general consensus of the league is that the Urban Achievers did not receive commensurate value from the Road Runners in the subject 6-player trade.  However, now tempers seemed to have flared to the point where the league is more suspicious about under-the-table dealings between the two teams. 

In the previous case, the Court ruled that there was no conclusive evidence of collusion to warrant immediate denial of the deal.  See Id. at 48.  The Court further held that the fact that league members are close friends is not demonstrative in and of itself 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).  Given that this is the second instance of suspicious dealings between these teams, the Court’s skepticism of the teams’ intent has been greatly elevated.  In addition, the gross imbalance of the trade only heightens the scrutiny leaving the Court no other option but to draw a reasonable inference that collusion, or some other form of tacit agreement between the two teams, exists. 

At first glance, the trade of Tim Lincecum, Chris Coghlan and Brett Wallace in exchange for Carlos Beltran, Roy Halladay and Albert Pujols looks tremendously uneven, imbalanced, and inequitable.  There are a plethora of superstars involved in this deal which always increases the level of scrutiny.  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 only reasonable exchange in the trade is Lincecum for Halladay.  While Halladay is objectively better in terms of fantasy statistics, rational arguments can be made to trade him for Lincecum.  Further, dealing Coghlan for Beltran is imbalanced despite the fact they were both newly drafted players in the Angerthal League’s 2011 draft.  In fact, Coghlan cost $11.00 while Beltran only cost $10.00.  This was likely due to the fact Beltran was coming off of two injury-plagued seasons and he was not projected to play every day due to his chronic knee conditions.  However, Beltran has excelled offensively all season and has played almost every game outside of missing some time due to the flu.  He has performed so well that he was the subject of a bidding war prior to the MLB trade deadline and was dealt to the defending World Champions to lead their offense down the stretch.  On the other hand, Coghlan has underperformed all year and has been on the disabled list since June.  Finally, the exchange of Pujols for Wallace completely shocks the conscience in terms of inequality and underlying suspicion of the trade itself.  While Pujols has had a down year compared to his season averages, and also missed two weeks with a broken wrist, he still has accumulated quite impressive statistics that dwarf the accomplishments of Brett Wallace. 

The following chart represents a statistical comparison between the six players in the relevant roto categories as of July 29, 2011:

Player

AVG.

HR

RBI

Runs

SB

Albert Pujols

.276

23

63

63

6

Brett Wallace

.272

4

26

35

1

 

 

 

 

 

 

Carlos Beltran

.286

15

66

61

3

Chris Coghlan

.230

5

22

33

7

 

 

 

 

 

 

Player

Wins

ERA

K’s

WHIP

Saves

Roy Halladay

12

2.55

147

1.04

0

Tim Lincecum

9

2.78

152

1.19

0

As can be seen from this comparison, the Road Runners are receiving a tremendous windfall in the deal when comparing the players involved. 

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 trade involves the even exchange of a starting pitcher, first baseman, and an outfielder.  As a result, there were no specific positional needs by either team.  The next part of the analysis would center around the particular categorical needs by each team.  The Court is unaware of the Angerthal League’s current overall standings, but it can still draw a reasonable inference that the Urban Achievers did not enter into this trade for the purpose of improving its position in the standings or in any particular scoring category.  On the other hand, it is quite obvious why the Road Runners would seek to acquire Halladay, Pujols and Beltran.  They are already in first place and are simply trying to maintain that position by bolstering themselves at first base and outfield.  The Court is willing to accept Halladay and Lincecum as fantasy equals.  Based on the foregoing analysis, the needs of the Urban Achievers were clearly not met as this trade in no way shape or form helps them in any capacity. 

In terms of keeper league status and salary cap value, this is where arguments can be made to justify its approval.  Pujols’ contract is set to expire at the end of 2011, and Wallace is only in his first year of team control.  While it is common practice for teams in keeper leagues to trade off established stars to build for the future, there must be some demonstration of such intent manifested within the trade.  Here, the Urban Achievers had control over Roy Halladay for another year before having to decide to sign him to a LTC.  By trading him, they acquire a younger pitcher in Lincecum but is only under control through 2012.  Additionally, they traded Beltran for Coghlan when both players were just drafted this season.  Granted Coghlan is a lot younger than Beltran, but he is hardly projected as a star to be relied on in the future.  Plus, Beltran arguably still has several productive years left and costs the same amount as Coghlan.  So looking at the totality of the trade, the Court does not see enough evidence to demonstrate a rebuilding process by the Urban Achievers to justify making this trade.

As referenced in Smittydogs v. Moneyball, 1 F.J. 32, 34 (June 2010), the dichotomy between the Road Runners and Urban Achievers’ motivations is precisely why the Court must look at trades in keeper leagues differently than non-keeper leagues.  However, had this trade been made in a non-keeper league, the Court would ardently reject it. 

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).  While this trade may not be the most intelligent deal that could have been made by the Urban Achievers, it is certainly not unfair.  It is not up to the Court to make a determination on what is considered intelligent.  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). 

Here, a trade was proposed and agreed to between two teams on the opposite ends of the standings.  That in itself does not present an issue.  The problem that lies herein is the fact that these two teams have a history of making trades that raised suspicion from other league members.  While the previous trade was approved, this particular trade involves such a disparity in value that the Court cannot overlook.  The Court does not prefer to assert its authority by preventing teams from entering into mutually agreed-to trades, but it must protect the integrity of the league itself by thwarting any such illicit activity.  Lopsided trades throw off the competitive balance of the league and create a slippery slope for future trades.  See 4 Ponies v. Beaver Hunters, 3 F.J. 26, 29 (June 2011).  Based on the foregoing reasons, the Court hereby decides that the subject trade should be rejected.  If the teams still desire to trade with each other, they will have to continue to work on balancing the deal so that it comports with the objective criteria laid out by the Angerthal League and by the Supreme Court of Fantasy Judgment.  Further, because the Court inferred that there was some form of collusion or conspiracy involved, it is recommended that the Commissioner address these concerns with the Road Runners and Urban Achievers. 

IT IS SO ORDERED.

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