Victoria’s Secret vs. V-Men – 4 F.J. 106 (July 3, 2012) – Fantasy Baseball Trade Dispute (A.Craig/A.Ramirez/B.Parnell)

SUPREME COURT OF FANTASY JUDGMENT

Victoria’s Secret vs. V-Men

ON PETITION FOR WRIT OF CERTIORARI FROM THE ANGERTHAL LEAGUE

Decided July 3, 2012

Cite as 4 F.J. 106 (July 2012)

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.  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

Victoria’s Secret has made a trade with the V-Men.  Victoria’s Secret traded Juan Uribe (3B-LAD, $5.00 in the final year of his existing contract), Allen Craig (OF-STL, $16.00 in the first year of his existing contract), Mike Leake (SP-CIN, $7.00 in the first year of his existing contract) and Kevin Correia (SP-PIT, salary unknown in the final year of his existing contract) to the V-Men in exchange for the expiring contracts of Chris Young (OF-ARZ, $15.00), Bobby Parnell (RP-NYM, salary unknown), Aramis Ramirez (3B-MIL, $27.00) and Michael Fiers (SP-MIL, salary unknown).

According to the Angerthal League’s Commissioner, there are no accusations of collusion or other dialogue concerning this trade outside of the fact another league member disagreed with the approval of the trade and requested that it be submitted to the Court review. 

Issue Presented

(1)   Should the trade between Victoria’s Secret and the V-Men be upheld and approved?

Decision

The Supreme Court of Fantasy Judgment typically favors fantasy sports participants and teams’ ability to make moves, transactions, and trades.  People pay money to participate in fantasy leagues, and generally they should be afforded the freedom to manage their team accordingly.  Whether success is bred from that individual’s decision-making is purely left to some skill, luck, dedication, and savviness.  4 Ponies v. Carson City Cocks, 3 F.J. 13 (May 2011).

It is well documented that there is a different analysis of trades in a keeper league as opposed to a non-keeper league.  A trade that may look facially uneven or lopsided could easily pass muster in a keeper league.  Trades made between teams in a keeper league need to be analyzed by other factors besides merely comparing statistics.  Grave Diggers vs. Chilidogs, 4 F.J. 5, 8 (January 2012).  These other factors include salary cap flexibility, contractual status of players, and long-term planning at the expense of the current season.  Smittydogs vs. Moneyball, 1 F.J. 32, 33 (June 2010); Winners vs. Seven Shades of Shite, 3 F.J. 97, 102 (July 2011) (holding that team owners in keeper leagues with no hope of contending in the current season must make critical roster management decisions of whether to trade established players to help build for the future).

The Court will evaluate the objective merits of a deal and ensure that the integrity of the league is maintained.  Victoria’s Secret vs. C-Train, 2 F.J. 32, 35 (October 2010).  The Court will not undermine a fantasy owner’s ability to manage his/her team unless a deal is unfair or inequitable, ripe with collusion, or not in the best interests of the league.  Whether a trade is objectively   intelligent or popular will not be part of the analysis.  4 Ponies vs. 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.  Carson City Cocks vs. Stud Muffins, 3 F.J. 23, 24 (May 2011).

No evidence has been submitted indicating any alleged collusion or malfeasance.  As such, the Court will operate on the presumption that there is no collusive conduct between the parties.

At first glance, the trade of Juan Uribe, Allen Craig, Mike Leake and Kevin Correia in exchange for Chris Young, Bobby Parnell, Aramis Ramirez and Michael Fiers looks slightly uneven.  None of the players involved in this trade are considered elite fantasy players requiring additional scrutiny merely because of how valuable they are by name recognition or reputation.  See Steelers vs. Patriots, 3 F.J. 216, 220 (November 2011).  However, on its face, there does not appear to be equitable value being exchanged.

The following chart represents a statistical comparison between the six players in the relevant roto categories through games played on July 2, 2012:

 

Player

AVG.

HR

RBI

Runs

SB

Aramis Ramirez

.261

9

45

44

2

Chris Young

.215

8

19

18

2

 

 

 

 

 

 

Allen Craig

.322

13

43

28

1

Juan Uribe

.200

1

12

10

0

 

 

 

 

 

 

Player

Wins

ERA

K’s

WHIP

Saves

Bobby Parnell

1

3.00

31

1.24

1

Michael Fiers

3

2.29

41

1.06

0

 

 

 

 

 

 

Mike Leake

3

4.12

62

1.29

0

Kevin Correia

4

4.32

34

1.30

0

As can be seen from this comparison, the hitters’ collective statistics are a lot closer than one would anticipate when being presented with this trade.  The package of Ramirez and Young is statistically better than Craig and Uribe.  However, the difference is minimal in terms of their accumulated numbers to date.  Going forward, the same can be expected because Uribe has underperformed and been injured, and the Dodgers will likely seek a replacement or an upgrade at third base later in the season.  Further, Uribe has not come close to replicating the statistics he produced in 2010 with the Giants, which also happened to be a contract year for him.  Additionally, Chris Young started the 2012 season at an incredible pace before sustaining a shoulder injury which shut him down for several weeks.  While he has never been known to hit for a high average, he should be able to reach 20 homeruns and 20 stolen bases by the end of the season. 

The differential in the pitchers involved in the trade is more pronounced.  The combination of Parnell and Fiers provides a significant upgrade in the ERA and WHIP categories.  Parnell is also the current Mets’ closer, so he is the only one who can or will contribute saves.  Neither Leake nor Correia are known for missing bats, so they will not help in the strikeout category either.  Fiers has stepped in and pitched well for the Brewers replacing the injured Shaun Marcum and Marco Estrada.  With Milwaukee on the verge of falling out of playoff contention, they could end up trading Zack Greinke which would free up a spot in the rotation for Fiers on a permanent basis. 

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).  Victoria’s Secret is currently tied for 4th place and clearly is setting their sights on improving for this season.  In this league, the top four teams receive a monetary prize at the end of the season.  It is questionable whether obtaining Aramis Ramirez is considered an upgrade over Allen Craig.  Craig has amassed better statistics in fewer games and at bats, but he can be considered a health risk due to the many injuries he has sustained in his young career.  In that sense, Ramirez is more of a known entity and can be relied on at the CI or 3B position.  The acquisition of Young will also bolster their already impressive stolen base totals as they make a run at winning that category.

On the other hand, the V-Men are in 7th place and 10 points behind Victoria’s Secret in 4th place.  They are trading away four expiring contracts which is symbolic of a team in a keeper league looking to build for the future.  See Moneyball vs. 4 Ponies, 4 F.J 67, 68 (May 2012) (upholding the 4 Ponies’ trade of Hanley Ramirez for a package of younger and less expensive talent as part of building for future seasons).  In return, they are acquiring Correia and Uribe whose contracts also expire.  More importantly, they acquired Allen Craig and Mike Leake who are in the first year of their respective contracts and do have future value.

When a team owner in a keeper league no longer believes he has any hope for contending in the current season, he must make a critical roster management decision of whether to trade off established players in exchange for unknown entities in building for the future.  Winners v. Seven Shades of Shite, 3 F.J. at 102.  This is precisely what the V-Men have done in acquiring players like Craig and Leake who do have current value as well. 

A trade will be rejected when the Court cannot objectively ascertain any benefit to one of the teams and the net result in no way makes a team better now or in the future.  Los Pollos Hermanos v. Little Stumps, 3 F.J. 192, 195 (October 2011).  This trade benefits Victoria’s Secret in their pursuit of success in the current season.  The trade also provides V-Men with salary cap flexibility and two players to build around for the immediate future. 

The dichotomy between Victoria’s Secret and V-Men’s motivations is precisely why the Court must look at trades in keeper leagues differently than non-keeper leagues.  Smittydogs v. Moneyball, 1 F.J. at 34.  However, had this trade been made in a non-keeper league, the Court would likely reject it. 

Here, a trade was proposed and agreed to between two teams with differing priorities.  While the two packages are not completely equitable in terms of present-day value, the trade has discernible benefits for both parties without any specter of collusion.  Based on the foregoing reasons, the trade should be approved as it was made in good faith and within the best interests of the league.

IT IS SO ORDERED.

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