Catfish Hunters vs. Wyld Stallyns – 5 F.J. 4 (February 1, 2013) – Fantasy Baseball Trade (M.Kemp/C.Ross)

SUPREME COURT OF FANTASY JUDGMENT

Catfish Hunters vs. Wyld Stallyns

ON PETITION FOR WRIT OF CERTIORARI FROM
THE BASEBALL MASTERS FANTASY BASEBALL LEAGUE

Decided February 1, 2013
Cite as 5 F.J. 4 (February 2013)

Factual Background

A fantasy baseball league called the Baseball Masters Fantasy Baseball League (hereinafter referred to as “BMFBL”) is comprised of 12 teams and has been in existence since 2006.  The BMFBL, hosted on Yahoo, is a mixed AL/NL 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 (3) 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 BMFBL 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 BMFBL has a constitution which contains provisions for making trades and the process by which they are either approved or rejected.  The rules state, in pertinent part:

Section 3 – Trades

1. Trades are permitted between teams and must be processed through the league’s website.  This includes both teams accepting the proposal which is then sent to the league for a vote to determine whether the deal is approved or rejected.

2. Trades will only be rejected if more than 50% of the eligible league members vote against the subject trade.  A vote that results in a tie means the trade will be approved.

3. Trades should be approved by league members so long as they are free from collusion and make sense from both participating teams’ perspectives.

*          *          *          *          *          *

6. Teams may trade draft picks as compensation.

On January 30, 2013, a trade was made between the Catfish Hunters and Wyld Stallions.  The Catfish Hunters traded Matt Kemp (OF-LAD, in his final year of protection) and a 3rd round draft pick in 2014 to the Wyld Stallions in exchange for Cody Ross (OF-ARZ, eligible to be protected for two more years), a 1st 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 out for a league vote to determine whether the deal would be approved or rejected.  Only one team voted against the trade, so it was approved and processed.  On January 31, 2013, the dissenting league member submitted this case to the Court appealing the trade and claiming that it was unfair and lopsided in favor of the Wyld Stallyns due to the acquisition of Matt Kemp.

Issue Presented

(1)   Should the trade between the Catfish Hunters and Wyld Stallyns be upheld?

Decision

The BMFBL is governed by a constitution which explicitly states the league’s rules concerning trades and the process for approval.  The Court always advocates for leagues to have a written constitution because it provides all league members with actual notice of the rules and shifts the burden onto them to be in compliance.  Shawn Kemp is My Daddy vs. Fantasy Basketball League Commissioner, 2 F.J. 24, 25 (October 2010).  Unless there is a documented dispute with the commissioner or timely challenge to the rules, league members should be bound by such rules.  Rubik’s Pubes vs. League Commissioner, 4 F.J. 98, 100 (June 2012).   In addition, barring extenuating circumstances that would justify a deviation, the written rules and guidelines should be strictly adhered to.  See Justin Verlander’s School for People Who Don’t Pitch Good vs. Angel Pagan Worshippers, 3 F.J. 105, 106 (August 2011).

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 4 Ponies v. 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 Matt Kemp and a future 3rd round draft pick in exchange for Cody Ross and two future 1st round picks looks slightly uneven.  Kemp is an elite fantasy baseball player because of his substantial contributions in all five major roto categories.  He is entering his prime and is hitting in the middle of a potent Dodgers’ lineup which should provide plenty of opportunities to hit with runners on base while also providing sufficient lineup protection behind him.  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).

There is no statistical or pragmatic analysis to be performed that will ever conclude that Cody Ross represents equal or fair value for Kemp.  If the BMFBL 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.  See Willie McGee’s Beauty Parlor vs. Sizemore Matters, 4 F.J. 29, 30 (April 2012).

However, the BMFBL 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 Kemp and Ross are outfielders so the trade evens out from a positional standpoint. 

Kemp was entering the final season he was able to be protected by the Catfish Hunters.  According to the league’s rules, Kemp would automatically become a free agent at the end of the 2013 season and be eligible for the 2014 draft.  This demonstrates the Catfish Hunters’ motivation to obtain some form of compensation for Kemp rather than lose him for nothing.  Cody Ross will likely not be able to replicate Kemp’s statistics, but he is a serviceable outfielder who will get significant playing time after signing a three-year contract with the Arizona Diamondbacks. 

The real value the Catfish Hunters obtained for Kemp was the acquisition of two future 1st round draft picks.  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 any fantasy baseball league format, Kemp is regarded as a 1st round pick.  Here, the Catfish Hunters not only obtained an extra 1st round pick for 2013, but they also acquired one 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 the Wyld Stallyns perspective, the acquisition of Kemp makes perfect sense from two perspectives.  His acquisition demonstrates both a “win now” mentality as well as long-term draft strategy.  The record is devoid of both teams’ rosters and where they finished in the standings last year.  But the Court can surmise that the Wyld Stallyns believe they are on the precipice of a championship by giving up two valuable 1st round draft picks in exchange for Kemp.  They can also keep Kemp for the next three years as per the league’s rules regarding long-term contracts. 

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 Kemp and Ross.  The inclusion of two future 1st round draft picks provides the requisite fair and equitable compensation for a player of Kemp’s caliber.  The trade makes perfect sense from both teams’ perspectives and fulfills the needs of teams within a keeper league.  Based on the foregoing, the appeal of the league vote is denied and the trade should be upheld.

IT IS SO ORDERED.

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