Stud Muffins vs. Kramerdogs – 5 F.J. 113 (July 15, 2013) – Fantasy Baseball Trade Review (B.Phillips/A.Simmons/J.Soler)

SUPREME COURT OF FANTASY JUDGMENT

Stud Muffins vs. Kramerdogs

ON PETITION FOR WRIT OF CERTIORARI FROM
THE INCONTINENT LEAGUE

Decided July 15, 2013
Cite as 5 F.J. 113 (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 Stud Muffins traded Brandon Phillips (2B-CIN, $2.70 in the second year of his existing contract with one year remaining) and Yonder Alonso (1B-SD, $0.50 in the final year of his existing contract and will become a free agent at the end of the season) to the Kramerdogs in exchange for Andrelton Simmons (SS-ATL, $1.00 in the second year of his existing contract with one year remaining), Jorge Soler (OF-CHC, $0.50 in the minors and can be retained at this salary until he is promoted), Mark Melancon (RP-PIT, $1.00 in the first year of his existing contract with two years remaining), and Alex Wood (RP-ATL, $1.00 in the first year of his existing contract with two years remaining).

Issue Presented

(1)   Should the trade between the Stud Muffins and the Kramerdogs 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 Brandon Phillips and Yonder Alonso in exchange for Andrelton Simmons, Jorge Soler, Mark Melancon, and Alex Wood looks inequitable in terms of present day value.  None of the players involved in this deal are 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 deal is represents another “dump trade” where the Stud Muffins are out of contention at this point of the season and sent a star player like Brandon Phillips to the Kramerdogs who are competing for the championship in exchange for less expensive players and younger prospects.  See Speedboys vs. Kramerdogs, 5 F.J. 109 (July 2013) (rejecting a proposed trade of Paul Goldschmidt, Adam Wainwright and Rafael Soriano in exchange for Bryce Harper, A.J. Burnett, Trevor Rosenthal and Archie Bradley).  While dump trades can affect the competitive balance of the league, they still deserve rational consideration unless there is specific prohibition of such actions in the league’s rules.  See Yankees vs. Tips, 5 F.J. 98 (July 2013) (holding that the Court must defer to the league’s rules which specifically prevented dump trades from being allowed).  Here, there are no such rules so the Court is free to evaluate this trade on the merits.

This trade represents the dichotomy of keeper league trade strategy where one team in contention has a “win now” mentality by acquiring more expensive players who may not be under contract following the season, coupled with a trade partner who building for the future by selling off assets.  Knights vs. Seawolves, 5 F.J. 46, 48 (May 2013).  The Kramerdogs are only one point out of 1st place and are understandably in hot pursuit of taking over the top spot.  The acquisition of Brandon Phillips, the best second baseman in the National League, will go a long way in achieving that goal.  On the contrary, the Stud Muffins are in 8th place and looking to build for the future by trading away Phillips’ expensive contract and Alonso’s expiring contract.

The motivations of both teams seem readily apparent and in good faith.  However, a trade of this magnitude must be looked at very closely to ensure its present-day inequity does not go against the spirit of the league.  That is because lopsided trades can throw off the competitive balance of a league and create a slippery slope for future trades.  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.  See 4 Ponies vs. Beaver Hunters, 3 F.J. 26, 29 (June 2011).

Phillips is clearly the best player involved in this trade as he is the preeminent second baseman in an NL-only league such as this.  Phillips is currently second in the National League with 74 RBI to go along with a .266 batting average, 12 homeruns and 46 runs scored.  This is incredible production from such a scarce position.  Along with him, the Kramerdogs also acquired Yonder Alonso’s expiring contract.  He has been dealing with injuries during the first half and only produced a .271 batting with six homeruns and 29 RBI.  However, he does provide eligibility at multiple positions under the IL’s settings.

We must analyze whether the package of Simmons, Soler, Melancon, and Wood is sufficient enough to pass muster.  Simmons is the key player in this package going to the Speedboys at shortstop, which is another scarce position.  In just his second season, Simmons is only batting .242 but does have eight homeruns and 30 RBI while typically batting leadoff for the Braves.  His 50 runs scored and five stolen bases can be improved upon with better plate discipline and an increased on base percentage.  In an NL-only league, Simmons can easily become a top shortstop option with continued growth and improvement.

Cubs’ outfield prospect Jorge Soler is currently injured after fouling a ball off of his shin in the minor leagues.  After the debut of Dodgers’ rookie Yasiel Puig earlier this year, many comparisons were made to Soler and the hope that the Cubs would give him a similar opportunity.  However, due to Soler’s injury there is very little chance that he will be promoted to Chicago this season.  Despite some disciplinary issues earlier this year with charging the opposing dugout with a bat and also failing to run hard, Soler is still considered a top prospect.

Mark Melancon is only 28-years old and is well-traveled already.  But he has apparently found his niche as a middle reliever for the Pirates which earned him an All Star berth.  Melancon finished the first half 2-1 with two saves, a microscopic 0.81 ERA and 0.78 WHIP, and is averaging more than a strikeout per inning.  With Jason Grilli leading the National League in saves, it is unlikely that Melancon will get many save opportunities this year.  But he is helpful in other peripheral categories.

Alex Wood, a second round draft pick in 2012, reached the major leagues very quickly and has been productive in the Braves’ bullpen thus far.  The long-term plan for Wood is to be a starter, but the Braves have plenty of depth in their rotation right now and needed help in the bullpen due to the losses of Johnny Venters and Eric O’Flaherty.

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).  The Speedboys unquestionably suffer a major downgrade at second base by trading away Phillips.  But they are in rebuilding mode and did acquire a less expensive shortstop that can be productive for them in 2014.  Soler is still a top prospect and can be retained indefinitely for only $0.50 until he is promoted.  Wood is another Atlanta pitching prospect who could be given an opportunity to start in 2014.  Melancon, while only a middle reliever, has put up such incredible numbers that he will help the Speedboys offset the horrendous ERA and WHIP of Heath Bell and J.J. Putz that is currently marring their starting lineup.

White it is normally acceptable for teams in keeper leagues to make trades that do not have equivalent present-day value, a deal that is so completely lopsided and goes against the best interests of the league will be rejected.  See Smittydogs vs. Moneyball, 4 F.J. 57 (May 2012) (rejecting a trade of Ryan Braun and Edwin Jackson in exchange for Randall Delgado, Dee Gordon and Bobby Abreu); Team Sabo vs. 4 Ponies, 4 F.J. 50 (May 2012) (rejecting a trade of Joey Votto and Tyler Clippard in exchange for Drew Stubbs, Francisco Rodriguez and Starling Marte).  While Brandon Phillips is the best second baseman in the National League, he is not on the same level of Paul Goldschmidt or Adam Wainwright who were the primary trade targets in the deal that was rejected under Speedboys vs. Kramerdogs, 5 F.J. 109 (July 2013).

This trade makes sense from both teams’ perspectives.  The disparity in value between the packages exchanged is not so great to warrant rejection.  Based on the foregoing, the Court approves the trade between the Stud Muffins and the Kramerdogs.

IT IS SO ORDERED.

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