Polcats vs. Team Sabo – 5 F.J. 28 (April 23, 2013) – Fantasy Baseball Trade (J.Votto/M.Harvey)

SUPREME COURT OF FANTASY JUDGMENT

Polcats vs. Team Sabo

ON PETITION FOR WRIT OF CERTIORARI FROM
THE INCONTINENT LEAGUE

Decided April 23, 2013
Cite as 5 F.J. 28 (April 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 Incontinent League previously had 11 teams during the 2012 season.  Entering the 2013 season, the league added a 12th team known as the Polcats.  To help build their franchise, the Polcats were able to keep one player from each of the 11 other teams after their initial ten keepers were claimed.

The Polcats traded Joey Votto (1B-CIN, $4.30 in the first year of his existing contract with two years remaining) and Edward Mujica (RP-STL, $1.00 in the first year of his existing contract with two years remaining) to Team Sabo in exchange for Matt Harvey (SP-NYM, $0.50 in the second year of his existing contract with one year remaining) and Jerry Hairston (3B-LAD, $0.10 in the first year of his existing contract with two years remaining).

Issue Presented

(1)   Should the trade between the Polcats and Team Sabo 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 Joey Votto and Edward Mujica in exchange for Matt Harvey and Jerry Hairston looks inequitable.  Votto is an elite fantasy player which would require additional scrutiny in a trade because of how valuable he is.  See Steelers vs. Patriots, 3 F.J. 216, 220 (November 2011).  Given that the Incontinent League is NL-only, Votto is arguably the best first baseman in the league.

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 follows several other deals recently consummated by the Polcats who is a new member of the league.  See Polcats vs. 4 Ponies, 5 F.J. 21 (April 2013); Polcats vs. Moneyball, 5 F.J. 25 (April 2013).  It has been disclosed that the Polcats’ strategy upon entering the league was to trade away expensive players and build a foundation for the future.  This is one of the key elements of participating in a keeper league where success must be sustained both in the present and the future.  As indicated in the above-referenced cases, the Polcats were allowed to build their roster by selecting players to keep from each of the other 11 teams after those teams claimed their respective keepers.  After doing so, they have traded away players such as Stephen Strasburg, Tim Hudson and Dominic Brown in an attempt to accumulate less expensive talent. 

Much like Strasburg, Joey Votto is in the first year of his contract and the Polcats could have had him for two more years.  He is arguably the best first baseman in the NL-only Incontinent League.  But for $4.30 per season, Votto represents almost 13% of the Polcats’ entire in-season salary cap.  Similar to Strasburg (who cost $4.40), this could be prohibitive for the Polcats to make further moves in an attempt to bolster his team.  By making this trade, the Polcats will save $4.70 which is significant.

In addition, Mujica is the Cardinals’ closer for the immediate future with Jason Motte on the disabled list and Mitchell Boggs failing miserably in the role.  That is not to say Mujica will remain the closer for the rest of the year, but for now he represents a viable candidate to accumulate saves.

Could the Polcats have obtained a better package of players for the NL’s preeminent first baseman and a closer on a good team?  That is distinctly a possibility.  However, teams are not obligated to shop players around for a more advantageous deal solely to appease potential criticism or second-guessing.  It is not up to the Court to make a determination on what is considered intelligent from each team’s perspective.  Allegedly unwise decisions should not be scrutinized or vetoed merely because they are allegedly unwise.  See Road Runners vs. Urban Achievers, 3 F.J. 47, 50 (June 2011) (holding that the main criteria for evaluating a trade is its inherent fairness, not whether it was an intelligent decision by a league member to make the deal).  Rather, the Court’s role is to ensure that the integrity of the league is maintained.  Victoria’s Secret vs. C-Train, 2 F.J. at 35.

When looking at the compensation provided by Team Sabo, the Court concludes that there is cognizable value.  The Polcats obtained Matt Harvey who has quickly become one of the biggest rising stars in all of fantasy baseball.  As of the date of this trade, Harvey is 4-0 with a 0.93 ERA.  He also leads the league in WHIP (0.65) and ranks second in strikeouts (32).  Harvey’s current salary is $0.50 and he is under control at that price for 2014 as well.  This could easily be one of the biggest bargains in the entire league.  On the other hand, Hairston represents little to value outside of having eligibility at multiple positions and only costs $0.10.

Trading a player like Votto could undoubtedly change the landscape of the league in terms of the current standings.  Team Sabo is currently in 3rd place and bolsters his ability to remain near the top of the standings throughout the season.  However, Votto does not come without risk given he missed significant time in 2012 with injuries and is still looking to regain his former MVP status. 

The Polcats are currently in 11th place and will likely remain towards the bottom of the standings for most of the season.  But as stated previously, they are a new franchise looking to build their roster for the future.  That being said, they did acquire a soon-to-be considered elite pitcher in Harvey.  That in itself represents a suitable replacement for the previously-traded Strasburg and gives the Polcats an ace to build around for next year.  Sacrificing the present for the future is unquestionably one of the justifiable reasons for making trades such as this in keeper leagues.

There are discernible benefits afforded to both teams despite the facially disparate value of the deal.  Had this trade been consummated in a non-keeper league, the Court’s evaluation may have been different.  However, this is a keeper league where teams have both short-term and long-term goals (especially a new franchise in the league).  Based on the foregoing, the Court approves the trade between the Polcats and Team Sabo.

IT IS SO ORDERED.

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