Gangrene Master Yoda vs. Team Dizzle – 4 F.J. 284 (October 11, 2012) – Fantasy Football Trade Review (P.Rivers/A.Johnson/R.White)

SUPREME COURT OF FANTASY JUDGMENT

Gangrene Master Yoda vs. Team Dizzle

ON PETITION FOR WRIT OF CERTIORARI FROM THE SHOWTIME FANTASY FOOTBALL LEAGUE

Decided October 11, 2012
Cite as 4 F.J. 284 (October 2012)

Factual Background

A fantasy football league called the ShowTime Fantasy Football League (hereinafter referred to as “SFFL”) has been in existence since 2002 and is comprised of 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 SFFL is a non-keeper redraft league hosted on the ESPN fantasy football platform.  The league utilizes the following scoring system:

Passing

  • Touchdown = 6 points
  • 25 yards = 1 point
  • Interception = -2 points
  • Two Point Conversion = 2 points
  • 300-399 yards = 2 points
  • 400+ yards = 5 points
  • Fumble lost = -2 points

Rushing

  • Touchdown = 6 points
  • 10 yards = 1 point
  • Two Point Conversion = 2 points
  • 100-199 yards = 2 points
  • 200+ yards = 5 points
  • Fumble lost = -2 points

Receiving

  • Touchdown = 6 points
  • 10 yards = 1 point
  • Two Point Conversion = 2 points
  • 100-199 yards = 2 points
  • 200+ yards = 5 points
  • Fumble lost = -2 points

Kicking

  • Extra Point = 1 point
  • Field Goal 17-49 yards = 3 points
  • Field Goal 50+ yards = 4 points

Team Defense/Special Teams

  • Touchdown (punt, kickoff, interception, fumble, blocked field goal or punt) = 6 points
  • 25 kickoff return yards = 1 point
  • 10 punt return yards = 1 point
  • Blocked punt, field goal or extra point = 2 points
  • Fumble recovery = 2 points
  • Sack = 1 point
  • Interception = 2 points
  • Safety = 2 points
  • 0 points allowed = 10 points
  • 2-6 points allowed = 8 points
  • 7-13 points allowed = 6 points
  • 14-17 points allowed = 4 points
  • 18-21 points allowed = 2 points
  • 28-34 points allowed = -1 point
  • 34-45 points allowed = -2 points
  • 46+ points allowed = -4 points

Teams are permitted to make trades with each other.  Once trades are agreed to through the league’s website, they are immediately sent to the commissioner who has the final authority and ultimate discretion to approve or reject the deal. 

Procedural History

On October 11, 2012, the team known as Gangrene Master Yoda made a trade with the team known as Team Dizzle.  Gangrene Master Yoda traded Roddy White (WR-ATL), Alex Smith (QB-SF), and Pierre Thomas (RB-NO) to Team Dizzle in exchange for Andre Johnson (WR-HOU), Shonn Greene (RB-NYJ) and Philip Rivers (QB-SD).

The SFFL commissioner has submitted this case to the Court to review whether the trade is fair and equitable.

Issue Presented

(1)   Should the trade between Gangrene Master Yoda and Team Dizzle be approved or rejected?

Decision

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.  See 4 Ponies vs. Carson City Cocks, 3 F.J. 13 (May 2011).

The Court will evaluate the objective merits of a deal and ensure that the integrity of the league is maintained.  See 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.  See Road Runners vs. 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).  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).

The SFFL is a non-keeper league which requires a different analysis of equitability as compared to a dynasty league.  When analyzing a trade in a non-keeper league, there is no need to consider the long-term benefits of the players for either team.  Willie McGee’s Beauty Parlor vs. Sizemore Matters, 4 F.J. 29, 30 (April 2012).  Instead, the Court will evaluate the merits of the players only in terms of the present season, including their statistical performances to date and their projected value for the remainder of the year.

Here, the commissioner has been granted the authority to approve or reject all trades that are proposed between league members.  The Court supports this type of arrangement where league members do not have the power to veto trades.  See Rubik’s Pubes vs. League Commissioner, 4 F.J. 98, 100-101 (June 2012) (holding that league members tend to base their subjective decisions on their own respective agendas rather than objectively evaluate the merits of a trade between other competing teams).  Because the commissioner has the authority to make these decisions, he has utilized his discretion to seek the Court’s opinion on whether the subject trade should be approved.

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 Roddy White, Alex Smith and Pierre Thomas in exchange for Andre Johnson, Philip Rivers and Shonn Greene looks equitable.  Both White and Johnson are high-profile wide receivers and the fact they are on opposite sides of this trade tends to balance the compensation for the most valuable players. 

Rivers has been a high-end quarterback throughout his career but he has never ascended to the next level despite having several offensive weapons at his disposal.  In a league that penalizes quarterbacks for throwing interceptions, Rivers productivity can be affected by offsetting positive points for turnovers.  In comparison, Smith has never been regarded as a viable fantasy option until this season.  San Francisco relied heavily on its defense and running game to reach the NFC Championship after the 2011 season.  However, thus far in 2012 the 49ers offense has gelled overall including some very impressive performances by Smith both passing and running the ball himself.

In terms of the running backs involved in the deal, both Greene and Thomas can be considered disappointments.  The Jets all but gave Greene their offense on his back with an alleged commitment to the running game that is now without LaDainian Tomlinson.  However, he has been sluggish and hasn’t been productive at all this season.  Thomas is one of several running backs on the Saints who heavily rely on their passing game.  Because New Orleans’ defense has been awful, the Saints have had to abandon the running game altogether too many times thus far.  Thomas cannot be counted on for many carries or scoring opportunities.

According to the SFFL’s scoring system, the players involved in this trade have accumulated the following point totals:

Roddy White              67 points          Andre Johnson            40 points

Alex Smith                  96 points           Philip Rivers                  86 points

Pierre Thomas            32 points         Shonn Greene               27 points

TOTALS                    195 points                                               153 points

As can be seen above, the point differential in the packages exchanged is 42 points.  While the equitability of a trade cannot be solely determined by the point differential between the sides, it is demonstrative of the deal’s fairness.  See You’re F***in’ Out, I’m F***in’ In vs. NY KrackaKillaz, 4 F.J. 279 (October 2012).  The biggest disparity in points amongst the players is Roddy White and Andre Johnson with a total of 27.  However, they have equitable fantasy value and their point totals are not drastically different so as to create an imbalance.

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).  Here, this three for three player trade involves the exchange of a quarterback, a running back, and a wide receiver.  Roddy White and Andre Johnson are two of the better receivers in the league, but White is marginally more valuable due to the fact that Johnson has a history of injuries and the Texans do not typically pass the ball as often as the Falcons.  However, they are a fair and even exchange for each other.

On its face, Philip Rivers is more valuable than Alex Smith based purely on comparing their career statistics.  However, Rivers regressed in 2011 with a propensity for throwing interceptions and dealing with various injuries to his offensive weapons.  Thus far in 2012 it has been a similar situation with players such as Ryan Mathews, Antonio Gates and Vincent Brown all missing time.  The loss of Vincent Jackson cannot be underscored either.  In comparison, Alex Smith appears to have matured and become a viable fantasy option at quarterback.  He has been given several new players at key positions to rely on and it has translated into an impressive offensive output to date. 

The exchange of running backs represents a swap of mediocre disappointments.  Green’s average yards per carry has prompted the Jets to give backup Bilal Powell more snaps during the past few games.  Green has only found the end zone once this season.  The depletion of the Jets’ wide receivers has also allowed opposing defenses to stack the box without fear of a deep pass burning them.  This has had a significant detrimental effect on Greene all season.  Pierre Thomas is just one of several running backs on the Saints who have had little to no impact whatsoever.  New Orleans relies heavily on its passing game behind Drew Brees, and when they do run the ball there is a distribution of carries amongst all rushers to diminish any value for one over another.

This trade does not present a noticeable upgrade or downgrade for either team when analyzing whether the deal includes equitable compensation.  Both teams clearly believe the deal will improve their respective rosters.  Whatever their motivations are for making this trade are irrelevant so long as the deal is fair and free from collusion.  Fantasy owners are free to prioritize which areas of their team that they want to pursue improvement in when making trades and managing their rosters.  Stud Muffins vs. Cajun Crawdads, 4 F.J. 61, 63 (May 2012).

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 vs. Little Stumps, 3 F.J. 192, 195 (October 2011).  Here, both teams assume similar risks and could reap similar rewards.  Additionally, there is fair value being exchanged.  Based on the foregoing, this trade should be approved by the SFFL commissioner. 

IT IS SO ORDERED.

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