Guns & Moses vs. Weapons of Mass Destruction – 5 F.J. 11 (February 28, 2013) – Fantasy Baseball Trade Dispute (F.Hernandez/D.Fister/G.Holland)

SUPREME COURT OF FANTASY JUDGMENT

Guns & Moses vs. Weapons of Mass Destruction

ON PETITION FOR WRIT OF CERTIORARI FROM
THE TOUGH GUYS FANTASY BASEBALL LEAGUE

Decided February 28, 2013
Cite as 5 F.J. 11 (February 2013)

Factual Background

A fantasy baseball league called the Tough Guys Fantasy Baseball League (hereinafter referred to as “TGFBL”) is comprised of 12 teams and has been in existence since 2009.  The TGFBL is an AL/NL mixed keeper league where each team must keep a minimum of five (5) players from one season to the next within its 23-man roster.  Each individual player may be retained by the same team for a maximum of three (4) consecutive years starting the following season after he is acquired before returning to the free agent pool and being eligible to be drafted again. 

As with many rotisserie leagues, the TGFBL 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 this roto league.

The TGFBL does not have a written constitution delineating the league’s rules.  However, because this is a keeper league, trades are permitted during the offseason.  All trades must be approved by the commissioner before they are applied.  There is no league vote option and the commissioner has the final say on all trades.

On February 26, 2013, a trade was made between Guns & Moses (“G&M”) and the Weapons of Mass Destruction (“WMD”).  G&M traded Felix Hernandez (SP-SEA, in the final year he can be protected) and a 3rd round draft pick in 2013 to WMD in exchange for Doug Fister (SP-DET, eligible to be protected for two more years), Greg Holland (RP-KC, eligible to be protected for three more years), a 2nd round draft pick in 2013, and a 1st round draft pick in 2014.

Procedural History

After the trade was agreed to by the teams, it was sent to the commissioner for approval.  The commissioner subsequently approved the trade and it was processed.  However, another team in the league complained to the commissioner that the trade wasn’t fair and should not have been approved.  The commissioner stood by his decision but agreed to submit the case to the Court for a final determination. 

Issue Presented

(1)   Should the trade between Guns & Moses and the Weapons of Mass Destruction be upheld?

Decision

The Court strongly advocates for fantasy sports leagues to be governed by a written set of rules within a constitution or charter.  However, we recognize that many leagues still operate without such formalities.  Despite the absence of a constitution, the commissioner is still empowered with the tasks of creating the league’s rules, settings, and guidelines.  Bryan LaHair Club For Men vs. League Commissioner, 4 F.J. 26, 28 (April 2012).  Included in those settings is the commissioner’s choice to autonomously handle approval of trades or opt for a league vote to determine whether a deal is approved.  Since the TGFBL’s inception, the commissioner has been the sole approver of trades.

It is well-established law 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 Felix Hernandez and a future 3rd round draft pick in exchange for Doug Fister, Greg Holland, a 2nd round pick in 2013, and a 1st round pick in 2014 looks slightly uneven.  Hernandez is an elite fantasy baseball player because of his substantial contributions in four of the five roto pitching categories.  While still relatively young, he has firmly established himself as one of baseball’s best pitchers and consistently produces exceptional statistics despite playing for a less than average Seattle team.  His status as an elite player requires additional scrutiny to ensure that fair compensation is being provided for him.  Steelers vs. Patriots, 3 F.J. 218, 220 (November 2011).

If the TGFBL was a non-keeper league, then this trade would be immediately rejected because there is such an imbalance between the values provided for only the current season.  There would be no reason to consider any long-term ramifications since the draft picks would likely not be compensable.  See Willie McGee’s Beauty Parlor vs. Sizemore Matters, 4 F.J. 29, 30 (April 2012).

However, the TGFBL is a keeper league.  The analysis for evaluating trades is much different in a keeper league than a non-keeper league.  See Grave Diggers vs. Chilidogs, 4 F.J. 5, 8 (January 2012); see also Harem Hawkings vs. Harbor Yankees, 4 F.J. 40, 42 (April 2012) (holding that a more expensive player could be financially prohibitive in the long run compared to a cheaper player who offers more financial flexibility).  A trade that may look facially uneven or lopsided may receive a different opinion when it is involved in a keeper league.  In a keeper league, teams must consider trading established players whose contract may be expiring in exchange for younger, less expensive players and/or future draft picks.  The decision-making process in a keeper league must include foresight and long-term considerations as opposed to non-keeper leagues where only the current season is considered.

When analyzing the fairness and equity of a trade, the Court will consider both teams’ needs to assess whether the trade subjectively makes sense from both perspectives.  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).  The record is devoid of both teams’ rosters, but all players involved in the deal are pitchers so the trade evens out from a positional standpoint. 

Hernandez is entering the final season in which he can be protected by G&M.  After this season, he would become a free agent and return to the draft since teams can only protect players for four consecutive seasons.  This demonstrates G&M’s motivation to obtain some form of compensation for Hernandez rather than lose him for nothing.  See Catfish Hunters vs. Wyld Stallyns, 5 F.J. 4 (February 2012) (upholding a trade of Matt Kemp and a future draft pick in exchange for Cody Ross and two future draft picks based on the impending expiration of Kemp’s contract in a keeper league).  Fister and Holland will likely not be able to replicate Hernandez’s statistics, but they are respectable pitchers who will provide contribution in all five roto categories. 

While Fister and Holland are serviceable options for G&M, the real value they obtained in this deal is the additional 2nd round pick in 2013 and a 1st round pick in 2014.  Draft picks in subsequent seasons are assets commonly bartered in keeper leagues.  See Bald Eagles vs. Weasel D, 3 F.J. 205, 208 (November 2011).  In most fantasy baseball league formats, Hernandez is regarded as a top ten pitcher and, according to FantasyPros.com, has an ADP of 30 which projects to being a 3rd round pick in a 12-team league.  Here, G&M not only obtained an extra 2nd round pick for 2013, but they also acquired a 1st round pick for 2014.  This puts them in prime position to restock their roster with quality players and be set up for the next cycle of player protection.  From WMD’s perspective, the acquisition of Hernandez makes perfect sense in fulfilling both a “win now” mentality and also adding an elite fantasy pitcher that can be protected for the next four years. 

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.  See Los Pollos Hermanos vs. Little Stumps, 3 F.J. 192, 195 (October 2011).  Here, there are clear benefits to both teams despite such a major disparity between the active players involved.  The inclusion of two future draft picks provides the requisite fair and equitable compensation for a player of Hernandez’s caliber.  The trade makes sense from both teams’ perspectives and fulfills the needs of teams within a keeper league.  Based on the foregoing, the commissioner’s decision to approve the trade is upheld.

IT IS SO ORDERED.

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