Smittydogs vs. Moneyball – 4 F.J. 57 (May 15, 2012) – Fantasy Baseball Trade Rejected (Braun/E.Jackson/D.Gordon)

SUPREME COURT OF FANTASY JUDGMENT

Smittydogs vs. Moneyball

ON PETITION FOR WRIT OF CERTIORARI FROM THE INCONTINENT LEAGUE

Decided May 15, 2012

Cite as 4 F.J. 57 (May 2012) 

Factual Background

A rotisserie fantasy baseball league called The Incontinent League (hereinafter referred to as “roto league” or “IL” is an 11-team NL-only keeper league utilizing an auction-style draft and transaction platform.  Teams are permitted to maintain up to ten (10) players during each off-season with individual players allowed to be kept for a maximum of three (3) consecutive years under contract.  Each team is also permitted to keep two minor league players which are in addition to the ten players kept.  This roto league also has a $26.00 draft salary cap, as well as a $36.00 in-season salary cap that is applicable for all teams.   

As with many rotisserie leagues, the Incontinent 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.

The Incontinent League submitted a proposed trade between two league members and seeks an opinion on whether the trade should be approved.

Procedural History

The Smittydogs made a trade with Moneyball.  The Smittydogs traded Ryan Braun (OF-MIL, $4.40 with one year remaining on his existing contract) and Edwin Jackson (SP-WAS, $2.20 with one year remaining on his existing contract) to Moneyball in exchange for Randall Delgado (SP-ATL, $0.50 with two years remaining on his existing contract), Dee Gordon (SS-LAD, $0.50 with one year remaining on his existing contract), and Bobby Abreu (OF-LAD, $1.00 with two years remaining on his existing contract).

Issue Presented

(1)   Should the trade between Smittydogs and Moneyball be approved?

Decision

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 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 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.  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.  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 Ryan Braun and Edwin Jackson in exchange for Randall Delgado, Dee Gordon and Bobby Abreu does not look fair and equitable.  In this deal, Braun is the only player regarded as elite.  He is indisputably one of the best fantasy players in baseball, especially in an NL-Only league such as the Incontinent League.  Any trade involving premier fantasy players is going to require additional scrutiny merely because of how valuable they are.  See Steelers vs. Patriots, 3 F.J. 218, 220 (November 2011).  In this case, Braun, the controversial National League MVP, is one of the top players in the entire IL.  Despite a slow start to the season and the loss of Prince Fielder’s presence in the lineup, Braun is still hitting .305 with 10 homeruns, 21 RBI, 6 stolen bases, and 25 runs scored.  In addition to Braun, Edwin Jackson is a very serviceable fantasy pitcher who has been the victim of poor run support and a shaky Nationals’ bullpen.  He only has one win thus far, but he has a very respectable 3.71 ERA, 38 strikeouts, and 1.00 WHIP. 

In comparison, Randall Delgado and Dee Gordon are young players with a lot of upside.  Delgado struggled to begin the 2012 season but has put together three consecutive solid starts showing signs that he could become a fixture in the Braves’ starting rotation.  Gordon emerged in 2011 as a spark plug for the Dodgers but has struggled to consistently hit major league pitching.  He possesses tremendous speed and stolen base potential, so he does have inherent value.  Bobby Abreu is in the twilight of his career and caught on with the Dodgers after he was released earlier this season by the Angels.  With Matt Kemp on the disabled list, Abreu may get some consistent at bats out of necessity.  But based on his statistics, there is no question that Abreu’s best days are behind him as he no longer hits for average or power, and his stolen base totals have become non-existent.

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 a swap of a starting pitcher and an outfielder with a shortstop thrown in.  The Smittydogs already have Rafael Furcal at shortstop and Tyler Pastornicky as a middle infielder, so it appears Gordon would either provide roster depth at those positions or he would be slotted in for Pastornicky who does not provide much in terms of offense.  Based on this analysis, positional needs were a minimal factor in the parties’ rationale for making the deal.  Moneyball clearly obtains an upgrade in the outfield with Braun who is one of the top three National League outfielders (besides Matt Kemp and Justin Upton).   On the other hand, the Smittydogs are now left with Logan Morrison, Xavier Nady, Juan Rivera, Ty Wigginton, Brett Pill and Abreu as its outfield options.  This marks a severe downgrade in quality by removing Braun from the roster.  Only Morrison can be considered an everyday player, and he even sits against certain left-handed pitchers.  While Jackson has more experience, he tends to be erratic and is not a sure thing in terms of fantasy production.  Given that, he could arguably be considered a wash for Delgado who does possess an unknown quantity of talent as well. 

The exchange of Braun for Abreu is completely lopsided.  Besides the fact Abreu is a part-time player at best at this stage of his career, there is a good chance he will not even be in the league next season.  Additionally, Jackson and Delgado can be considered fair value for each other.  Dee Gordon does not provide the Smittydogs with an upgrade over their incumbent players.   Under no circumstances can the Court comprehend how the Smittydogs benefit from this trade and resultant drastic downgrade in the outfield.  The value of a player such as Braun is not necessarily equivalent to the accumulation of several other less valuable players’ statistics or upside.  See Team Sabo v. Nub Vader, 3 F.J. 55, 56 (July 2011). 

In terms of the contractual and financial ramifications of the trade, there is a significant disparity in the salaries of both packages.  The Smittydogs would be saving $4.60 which represents just under 13% of each team’s allotted in-season salary cap.  That financial flexibility could be used in various ways.  On the other hand, Moneyball is adding $4.60 in salary but would be acquiring one of the premier players in the league and becoming an instant championship contender.  Coincidently, Moneyball is in 6th place and operating under a “win now” mentality while the Smittydogs are just 4.5 points behind Moneyball in 7th place and looking to build for the future. 

By trading Braun, it appears that the Smittydogs are conceding this season and trying to build for the future.  See Winners v. Seven Shades of Shite, 3 F.J. 97, 102 (July 2011) (holding that when a team in a keeper league no longer has any hope for contending in the current season, he/she must make a critical roster management decision of whether to trade off established players in exchange for unknown entities in building for the future).  While this is normally a justifiable reason to make a trade that doesn’t have present-day equivalent value, it does not permit teams to make completely lopsided trades that contradict the best interests of the league.  See Team Sabo vs. 4 Ponies, 4 F.J. 50 (May 2012) (holding that a proposed trade of Joey Votto and Tyler Clippard in exchange for Drew Stubbs, Francisco Rodriguez and Starling Marte should be rejected because it was completely lopsided and inequitable).  The Court fails to see how this trade remotely benefits the Smittydogs besides gaining salary cap flexibility.  The money saved along with the potential value of Delgado and Gordon is not enough to equitably justify trading one of the preeminent players in this NL-only league. 

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.  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 is not equitable and should be rejected.  The parties should have an opportunity to amend the deal to comport with the best interests of the league.   

IT IS SO ORDERED.

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