Moneyball vs. Beaver Hunters – 5 F.J. 78 (June 22, 2013) – Fantasy Baseball Trade Dispute (C.Kimbrel/J.Upton/D.Brown)

SUPREME COURT OF FANTASY JUDGMENT

Moneyball vs. Beaver Hunters

ON PETITION FOR WRIT OF CERTIORARI FROM
THE INCONTINENT LEAGUE

Decided June 22, 2013
Cite as 5 F.J. 78 (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

Moneyball traded Dominic Brown (OF-PHI, $1.80 in the first year of his existing contract with two years remaining) and Carlos Villanueva (RP-CHC, $1.00 in the first year of his existing contract with two years remaining) to the Beaver Hunters in exchange for Craig Kimbrel (RP-ATL, $0.50 in the final year of his existing contract) and Justin Upton (OF-ATL, $4.30 in the second year of his existing contract with one year remaining).

Issue Presented

(1)   Should the trade between Moneyball and the Beaver Hunters 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 Dominic Brown and Carlos Villanueva in exchange for Craig Kimbrel and Justin Upton looks slightly uneven in terms of present-day value.  Kimbrel and Upton are borderline elite players, especially in an NL-only league such as this.  In addition, Brown is emerging as a possible elite fantasy player.  As such, we must utilize a heightened amount of scrutiny when evaluating this trade.  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).

This trade is perfectly indicative of the keeper league dynamic where a team that is out of contention during the current season trades away its valuable assets in an attempt to build for the future.  The Beaver Hunters, currently in 11th place and 36 points out of a prize-winning slot, have made the critical roster management decision to punt the remainder of this year and build for the future.  See Winners vs. Seven Shades of Shite, 3 F.J. 97, 102 (July 2011).

As previously stated, trades made in a keeper league must be evaluated by other factors besides statistics.  See 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).  While Kimbrel is unquestionably the best closer in an NL-only league (despite Jason Grilli’s accomplishments to date), his contract will expire at the end of the season and he will be eligible to be drafted in 2014.  Rather than lose him for nothing, the Beaver Hunters decided to trade him and receive a useful asset in return.

In addition, Justin Upton’s salary is $4.30 which is a significant percentage of each team’s allotted salary cap to be tied up into one player.  Clearly the Beaver Hunters are looking to free up salary cap space in order to make additional moves or sign players to long-term contracts after the 2014 draft.  While Upton is perceived as an elite outfielder in an NL-only league, the fact remains that he brings along some inherent risk due to him being a streaky and inconsistent hitter.  He had an incredible April setting the league on fire with 12 homeruns, but he has been equally as brutal since.  Upton’s average has plummeted to .240 and is he has only hit three homeruns since that time.  However, he still possesses five-category talent and is hitting in the middle of a powerful lineup.

Since the Beaver Hunters are giving up such an impressive package of talent, the Court must ensure that they receive a discernible benefit from the compensation they receive from Moneyball.  Villanueva is nothing more than a middle reliever/spot starter for a bad Cubs team.  His peripheral numbers are respectable, but the fact remains that he does not provide much assistance in any one particular roto category.  On the other hand, Dominic Brown is blossoming into an elite fantasy outfielder.  Brown has finally been given the chance to play every day in Philadelphia and has rewarded the organization for its patience.  He is currently second in the National League with 19 homeruns and tied for fourth with 50 RBI.  The Beaver Hunters can have him for $1.80 for the next two seasons as well, so he is clearly an inexpensive star to build around for the future.

Moneyball, currently in 4th place, is clearly in a “win now” mentality by acquiring Kimbrel and Upton.  They will lose Kimbrel at the end of the season, so this is purely a rental in order to improve their place in the standings in terms of saves.  Moneyball is currently 10th out of 12 in saves, so this acquisition will easily help them accumulate more points in that category.  Upton does not necessarily represent an upgrade over Brown, but he is a serviceable replacement for Brown and only has one year left at the exorbitant salary of $4.30.

The Beaver Hunters appear to be out of contention for one of the top four money prizes this season.  However, their acquisition of Brown does present a significant and inexpensive cornerstone to build around for the next two years.  Both teams satisfied their respective goals and obtained discernible benefits.  Based on the foregoing, the Court approves the trade between Moneyball and the Beaver Hunters.

IT IS SO ORDERED.

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