Speedboys vs. Carson City Cocks – 5 F.J. 106 (July 15, 2013) – Fantasy Baseball Trade Review (J.Heyward/M.Ozuna)

SUPREME COURT OF FANTASY JUDGMENT

Speedboys vs. Carson City Cocks

ON PETITION FOR WRIT OF CERTIORARI FROM
THE INCONTINENT LEAGUE

Decided July 15, 2013
Cite as 5 F.J. 106 (July 2013)

Factual Background

A rotisserie fantasy baseball league called The Incontinent League (hereinafter referred to as “roto league” or “IL” is a 12-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’s commissioner submitted a proposed trade between two league members and seeks an opinion on whether the trade should be approved.

Procedural History

The Speedboys traded Jason Heyward (OF-ATL, $3.90 in the first year of his existing contract with two years remaining) to the Carson City Cocks in exchange for Marcel Ozuna (OF-MIA, $0.50 in the first year of his existing contract with two years remaining).

Issue Presented

(1)   Should the trade between the Speedboys and the Carson City Cocks be approved?

Decision

The Court has consistently ruled that people who participate in fantasy leagues should be given the freedom to manage their teams according to their own preferences.  Whether success is bred from that individual’s decision-making is purely left to some skill, luck, dedication, and savviness.  See Gangrene Master Yoda vs. Team Dizzle, 4 F.J. 284, 285 (October 2012); 4 Ponies vs. Carson City Cocks, 3 F.J. 13 (May 2011).

When presented with a dispute over the fairness or equitability of a trade, 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).  Typically, the approval or rejection of a trade is based on whether the deal was made without collusion, has equitable consideration, and comports with the best interests of the league.  See 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 Jason Heyward in exchange for Marcel Ozuna looks fair and equitable.  Neither player involved in this trade is considered elite for purposes of requiring additional scrutiny.  See Steelers vs. Patriots, 3 F.J. 216, 220 (November 2011).

The Incontinent League is a keeper league which can lead to a different evaluation of a trade as opposed to a non-keeper or redraft 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).

This trade represents a fair exchange of outfielders for one another who have had polar opposite seasons thus far.  Jason Heyward was a popular draft selection by many fantasy baseball pundits who prognosticated a breakout season in his fourth year and coming off a strong 2012.  Unfortunately for Heyward, it has been a disastrous season which started with an emergency appendectomy in April and ended the first half with a hamstring injury.  In between, Heyward needed a serious hot streak to bring his batting average up to .227 to go along with seven homeruns and 21 RBI.

On the other hand, Marcel Ozuna was recalled from the minor leagues to fill in for Giancarlo Stanton when the Marlins’ slugger sustained a hamstring injury in April.  Not only did Ozuna fill in admirably for Stanton, but he has become the Marlins’ cleanup hitter and a fixture in Miami’s outfield.  The 22-year old rookie finished the first half of the season with a .273 batting average to go along with three homeruns, 32 RBI, 31 runs scored and five stolen bases.  Those may not sound like fantasy-viable numbers, but considering that he is a rookie playing on an abysmal Marlins team it shows that can become a solid major league player for a long time.

Both players are in the first years of their respective contracts, but this trade represents the Carson City Cocks’ “win now” mentality by taking on Heyward’s $3.90 salary for the next couple years.  They are currently in 3rd place and only three points out of 1st place.  Heyward is expected to return after the All Star break.  Despite his struggles all season, Heyward still represents a significant upgrade over Ozuna.

On the other hand, the Speedboys are currently in 7th place and 23 points out of one of the prize-winning slots.  Their frustration with Heyward and willingness to give up on him is understandable, especially given the exorbitant salary he has attached to him.  The Speedboys were able to acquire a much less expensive starting outfielder which will provide more flexibility for future transactions.

This trade makes sense from both teams’ perspectives.  In a vacuum, Heyward is clearly the better player with a greater ability to contribute in several roto categories.  But given Heyward’s injuries, struggles and apparent regression, he does not possess the same inherent value that he did just six months ago.  Based on the foregoing, the Court approves the trade between the Speedboys and the Carson City Cocks.

IT IS SO ORDERED.

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