Carson City Cocks vs. Stud Muffins – 5 F.J. 75 (June 12, 2013) – Fantasy Baseball Trade Review (B.Phillips/G.Parra/F.Liriano)

SUPREME COURT OF FANTASY JUDGMENT

Carson City Cocks vs. Stud Muffins

ON PETITION FOR WRIT OF CERTIORARI FROM
THE INCONTINENT LEAGUE

Decided June 12, 2013
Cite as 5 F.J. 75 (June 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 Carson City Cocks traded Brandon Phillips (2B-CIN, $2.60 in the second year of his existing contract with one year remaining), Cody Ross (OF-ARZ, $1.30 in the first year of his existing contract with two years remaining), and Ross Detwiler (SP-WAS, $1.00 in the second year of his existing contract with one year remaining) to the Stud Muffins in exchange for Francisco Liriano (SP-PIT, $1.00 in the first year of his existing contract with two years remaining) and Gerardo Parra (OF-ARZ, $2.20 in the first year of his existing contract with two years remaining).

Issue Presented

(1)   Should the trade between the Carson City Cocks and the Stud Muffins 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, Cody Ross and Ross Detwiler in exchange for Francisco Liriano and Gerardo Parra looks slightly uneven in terms of present-day value.  None of the players involved in this trade are considered elite for purposes of requiring additional scrutiny simply because of how valuable they are.  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).

Brandon Phillips is arguably the best player in this deal because of his statistics and the fact he produces them at a scarce position like second base.  He is currently second in the National League with 52 RBI.  In this NL-only league, that is incredible production out of a second baseman which makes Phillips the best overall at the position.  On top of that, he possesses a .292 batting average with ten homeruns and 38 runs scored.

Along with Phillips, the Stud Muffins, currently in 9th place, acquired Cody Ross and Ross Detwiler.  Ross was injured to begin the season and still has not been able to rekindle the success he had the past couple seasons.  He has a .259 batting average with two homeruns and 16 RBI.  Despite signing a three-year contract with the Diamondbacks, he could possibly lose playing time when rookie Adam Eaton finally returns.  Detwiler is scheduled to come off the disabled list on June 13, 2013 after suffering an oblique injury.  He is 2-4 with a 2.75 ERA, 1.44 WHIP, and only 23 strikeouts in 45.2 innings.  Detwiler is a serviceable pitcher but hardly a top fantasy option.

This trade is somewhat of an anomaly because the Carson City Cocks, currently in first place, are trading away the most valuable player at a particular position.  But it makes sense given what they are receiving in return with Liriano and Parra.  Parra has emerged as a legitimate everyday outfielder for the Diamondbacks which is also reason enough why Cody Ross could see a decrease in playing time.  He has provided solid production across all five roto categories with a .318 batting average, five homeruns, 20 RBI, 42 runs scored and five stolen bases.

Liriano has been a polarizing fantasy pitcher for years as he is blessed with immense talent but always susceptible to injuries and inconsistency.  He suffered an injury this past winter and only made his debut with the Pirates a few weeks ago.  Since then, he has made six starts and compiled an impressive 4-2 record with a dazzling 1.75 ERA, 1.16 WHIP, and 47 strikeouts in just 36 innings.  Even more impressively he has kept his walks down only issuing 14 free passes all season.  Of course there is inherent risk with Liriano given his track record, but the Carson City Cocks needed an upgrade in their pitching in order to maintain their lead in the league.

Fantasy owners in roto leagues are faced with many strategic decisions when managing their rosters.  They are free to prioritize which categories they want to pursue improvement in when making trades and managing their rosters.  Joba’s Mustache vs. Obtuse Wardens, 5 F.J. 40, 41 (May 2013); Stud Muffins vs. Cajun Crawdads, 4 F.J. 61, 63 (May 2012).  This trade does leave the Carson City Cocks with a substantial downgrade at second base as Derek Dietrich is his only other player eligible at the position.  But he receives an upgrade in the outfield and in his pitching staff which could allow him to gain more points in categories that he is currently lacking.

The Stud Muffins appear to be out of contention for one of the top four money prizes this season.  However, their acquisition of Phillips does present a significant upgrade at a scarce position.  Phillips is also under contract for 2014 so the Stud Muffins are in position to contend next year assuming they make other necessary roster upgrades.  Both teams fill certain needs and the value of the players involves in the trade represent fair value.  Based on the foregoing, the Court approves the trade between the Carson City Cocks and the Stud Muffins.

IT IS SO ORDERED.

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