Polcats vs. Kramer Dogs – 5 F.J. 32 (April 23, 2013) – Fantasy Baseball Trade (M.Bumgarner/H.Ramirez/O.Taveras)

SUPREME COURT OF FANTASY JUDGMENT

Polcats vs. Kramer Dogs

ON PETITION FOR WRIT OF CERTIORARI FROM
THE INCONTINENT LEAGUE

Decided April 23, 2013
Cite as 5 F.J. 32 (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 Madison Bumgarner (SP-SF, $4.30 in the first year of his existing contract with two years remaining), Hanley Ramirez (SS-LAD, $2.50 in the first year of his existing contract with two years remaining), and Jorge Soler (OF-CHC, $0.50 in the minor leagues and under team control at that salary until he is promoted to the big leagues) to the Kramer Dogs in exchange for Starling Marte (OF-PIT, $0.50 in the first year of his existing contract with two years remaining), Elian Herrera (3B/OF-LAD, $1.00 in the first year of his existing contract with two years remaining), and Oscar Taveras (OF-STL, $0.50 in the minor leagues and under team control at that salary until he is promoted to the big leagues).

Issue Presented

(1)   Should the trade between the Polcats and the Kramer Dogs 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 Madison Bumgarner, Hanley Ramirez and Jorge Soler in exchange for Starling Marte, Elian Herrera and Oscar Taveras looks inequitable.  None of the players involved in the trade are considered elite which may require additional scrutiny in a trade because of how valuable a particular player is.  See Steelers vs. Patriots, 3 F.J. 216, 220 (November 2011).  However, Bumgarner is quickly ascending into the upper echelon of NL starting pitchers along with Clayton Kershaw, Stephen Strasburg, Matt Cain and Cliff Lee.  Additionally, Hanley Ramirez is no longer considered an elite fantasy player given the decline in his performance over the past several years as well as his injury history.

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); Polcats vs. Team Sabo, 5 F.J. 28 (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 Joey Votto, Stephen Strasburg, Tim Hudson and Dominic Brown in an attempt to accumulate less expensive talent. 

Much like Strasburg, Madison Bumgarner is in the first year of his contract and the Polcats could have had him for two more years.  He is one of the best starting pitchers in the National League and has taken his game to the next level after two consecutive solid seasons.  But for $4.30 per season, Bumgarner 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 $5.30 which is significant, especially when added to the savings achieved by making his previous trades.

Ramirez was once considered one of the top fantasy baseball players in the league.  He possessed the rare combination of high batting average, power and speed from a premium position.  But he suffered significant declines in his production in 2010 and 2011.  After a trade to the Dodgers in 2012, his homerun total and run production improved.  Despite missing the first month of the 2013 season with a finger injury sustained during the World Baseball Classic, Ramirez can still produce solid numbers at multiple positions. 

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 the Kramer Dogs, the Court concludes that there is value.  The Polcats obtained Starling Marte who could be a rising star as an outfielder for the Pirates.  He has gotten off to a great start to the 2013 season with a .315 batting average, 12 runs scored, and two stolen bases.  He can contribute solid numbers in all five roto categories and should develop more power as he gets older.  But the real gem in this package is Cardinals prospect Oscar Taveras.  Taveras has drawn comparisons to Vladimir Guerrero and could make a major impact upon his promotion sometime later this season or in 2014.  He will be under control at $0.50 for multiple seasons after he reaches the big leagues, so this could be a great bargain down the road for the Polecats.

Trading an ace pitcher like Bumgarner could undoubtedly change the landscape of the league in terms of the current standings.  The Kramer Dogs are currently in 4th place but in the middle of the pack in several pitching categories.  Bumgarner should help improve that over the course of the season.  However, after seeing what has happened to fellow Giant pitcher Tim Lincecum, one has to consider the possibility of a similar drop-off for Bumgarner in the next few years.  Lincecum threw an exorbitant number of innings at a very young age, and it is possible that the wear and tear on his arm has cost him several miles per hour on his pitches.  Bumgarner threw over 200 innings in 2011 and 2012.  He has gotten off to a great start in 2013 and will likely exceed 200 innings again.  Given that Bumgarner is under contract for the next two seasons, the possibility of a similar fate has to be at least considered.

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 solid outfielder in Marte who can contribute right away, as well as arguably the top prospect in baseball in Taveras.  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 the Kramer Dogs.

IT IS SO ORDERED.

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