Moneyball vs. 4 Ponies – 5 F.J. 161 (August 11, 2013) – Fantasy Baseball Trade Review (M.Minor/R.Halladay)

SUPREME COURT OF FANTASY JUDGMENT

Moneyball vs. 4 Ponies

ON PETITION FOR WRIT OF CERTIORARI FROM
THE INCONTINENT LEAGUE

Decided August 11, 2013
Cite as 5 F.J. 161 (August 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

Moneyball traded Roy Halladay (SP-PHI, $1.50 in the first year of his existing contract with two years remaining) and Todd Frazier (3B-CIN, $0.50 in the second year of his existing contract with one year remaining) to the 4 Ponies in exchange for Mike Minor (SP-ATL, $1.00 in the second year of his existing contract with one year remaining) and Daniel Murphy (2B-NYM, $0.10 in the final year of his contract and will be eligible for the draft in 2014).

Issue Presented

(1)   Should the trade between Moneyball and the 4 Ponies 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 Roy Halladay and Todd Frazier in exchange for Mike Minor and Daniel Murphy looks inequitable in terms of present-day value because Halladay is currently injured after undergoing shoulder surgery earlier this year.  However, Halladay is aiming to return before the season ends.  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).

Moneyball is currently in 1st place by only one point and is looking to maintain its lead in pursuit of the league championship this year.  Clearly Roy Halladay has been a complete bust due to his horrendous statistics and subsequent injury.  While he is scheduled to return at the end of August or early September, it was questionable whether he can be relied upon by Moneyball to maintain his position in the standings with respect to the pitching categories.  Mike Minor is a significant upgrade as he has emerged as the ace of the Braves’ staff compiling an 11-5 record with a 2.76 ERA, 1.04 WHIP and 137 strikeouts in 150 innings (not including his start on Sunday, August 11, 2013 versus the Marlins).

In addition to Minor, Moneyball also acquired Daniel Murphy’s expiring contract.  Murphy is a valuable second baseman/middle infielder given his batting average statistics which tend to be scarce at those positions.

By contrast, when a team owner 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 to help build for the future.  See Winners vs. Seven Shades of Shite, 3 F.J. 97, 102 (July 2011).  The 4 Ponies are currently in 6th place and 9.5 points out of one of the prize-winning slots.  It is apparent that they are conceding the current season since obtaining Halladay marks a downgrade for the remainder of this season.

However, if Halladay is healthy after his shoulder surgery, he could become a bargain for $1.50 over the next two seasons.  The 4 Ponies only would have had Minor through 2014, but here they obtain an extra year of Halladay who is under contract through 2015.  Granted there are inherent risks associated with Halladay given his age, the injury, and his own contractual status with the Phillies.  But there is enough potential upside for a team looking to rebuild such as the 4 Ponies.

The 4 Ponies also acquired Todd Frazier in this deal while giving up Murphy.  Murphy’s contract was set to expire at the end of the season, so the 4 Ponies were able to obtain some compensation for him rather than lose him for nothing.  Frazier started off the season productively but has had pedestrian number over the past couple months.  He still represents solid compensation for Murphy with a likely increase in power but a decrease in batting average.

This trade makes sense from both teams’ perspectives.  It personifies the dichotomy of trade strategy that exists in keeper leagues. On the one hand, the 4 Ponies are trying to build for the future by taking a chance on Halladay who is under contract for the next two years.  They also traded an expiring contract for a viable piece in Frazier.  On the other hand, Moneyball is trying to win right now and acquired a significant upgrade with Minor.  Based on the foregoing, the Court approves the trade between Moneyball and the 4 Ponies.

IT IS SO ORDERED.

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