In Pursuit of the Grail vs. Screaming Psychopaths – 6 F.J. 103 (April 27, 2014) – Fantasy Baseball Trade Review (R.Cano/J.Ellsbury/S.Marte)

SUPREME COURT OF FANTASY JUDGMENT

In Pursuit of the Grail vs. Screaming Psychopaths

ON PETITION FOR WRIT OF CERTIORARI FROM
THE COLLEGE AMIGOS FANTASY BASEBALL LEAGUE

Decided April 27, 2014
Cite as 6 F.J. 103 (March 2014)

Factual Background

A rotisserie fantasy baseball league called the College Amigos Fantasy Baseball League (hereinafter referred to as “CAFBL” was established in 1999 and is hosted on CBS.  The CAFBL is a 14-team mixed AL/NL keeper league utilizing an auction-style draft with a budget of $260.00 for 27 players.  Teams are permitted to maintain up to five (5) players during each off-season with players’ salaries increased by $2.00 multiplied by the number of years they have been kept.  The salary of a player acquired in the draft is his auction price.

As with many rotisserie leagues, the CAFBL 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.  The CAFBL applies a head-to-head format where each category is considered a win.

The CAFBL has a written constitution with rules and guidelines in place regarding trades.  The relevant rules pertaining to trades are as follows:

8. TRADES

8.3 Trades do not affect the salary or contracts of players.
8.4 Trades may only involve players in the instant trade and may not involve cash, players to be named later, or future considerations.

9. TRADE REVIEWS

9.1. Trades shall be referred to a 3rd party reviewer and that decision is final.
9.2 The 3rd party reviewer may consider the contract and salary of players for keeper purposes, but the primary considerations of review shall be preservation of the integrity and overall competitiveness of the current season.

The CAFBL’s commissioner submitted a proposed trade between two league members and seeks an opinion on whether the trade should be approved.

Procedural History

In Pursuit of the Grail traded Jed Lowrie (SS-OAK, $4.00 salary in 2014), Jacoby Ellsbury (OF-NYY, $37.00 salary in 2014), Rajai Davis (OF-DET, $7.00 salary in 2014) and Jonathan Broxton (RP-CIN, $5.00 salary in 2014) to the Screaming Psychopaths in exchange for Robinson Cano (2B-SEA, $32.00 salary in 2014) and Starling Marte (OF-PIT, $11.00 salary in 2014)

Issue Presented

(1)   Should the trade between In Pursuit of the Grail and the Screaming Psychopaths 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.

The CAFBL 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).

It should be noted that the CAFBL’s rules specifically state that the validity and equitability of trades shall primarily consider the overall integrity and competitiveness of the current season.  As such, the Court defers to the league’s guidelines for the standard of review.  This means that we will deviate somewhat slightly from the norm and focus on the immediate effect and impact of this trade rather than broaden the scope and break down the long-term benefits typically afforded in keeper league trades.  In Pursuit of the Grail vs. Screaming Psychopaths, 6 F.J. 5 (February 2014).

At first glance, the trade of Jed Lowrie, Jacoby Ellsbury, Rajai Davis and Jonathan Broxton in exchange for Robinson Cano and Starling Marte looks fair and equitable.  Cano and Ellsbury are considered elite players for purposes of requiring additional scrutiny merely because of how valuable they are based on his statistical production across the board  See Steelers vs. Patriots, 3 F.J. 216, 220 (November 2011).  When players of Ellsbury and Cano’s caliber are traded, it is imperative to make sure the compensation being exchanged is equitable and sensible irrespective of the number of players obtained in return.  A player’s value is not necessarily equivalent to the accumulation of several other less valuable players’ statistics.  See Team Sabo vs. Nub Vader, 3 F.J. 55, 56 (July 2011).

When a trade such as this is consummated involving the exchange of players at all different positions, it can reasonably be concluded that both GM’s have different interests and priorities with respect to the composition of their rosters.  See In Pursuit of the Grail vs. Reloading Again, 6 F.J. 12, 13 (March 2014).  GM’s in roto leagues are free to prioritize which categories they want to pursue improvement in when making trades and managing their rosters.  Team Sabo vs. 4 Ponies, 5 F.J. 167 (August 2013) (approving a trade where a team higher in the standings traded Mat Latos for Homer Bailey because he needed improvement in the WHIP category despite Bailey having better statistics with wins, ERA and strikeouts); 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).

It should be noted that while Ellsbury is an elite fantasy player, he is also classified as an injury risk.  Since becoming an everyday player in 2008, he has missed significant time in three subsequent seasons due to various injuries.  At 30-years old and with a game that is premised on speed with his legs, there is inherent risk in acquiring Ellsbury despite his undisputed talent.  Despite those risks and the fact he just recently traded a similarly risky Carlos Gonzalez, we can understand why the Screaming Psychopaths would want a player of Ellsbury’s caliber and the statistical production he brings to the table (.325 batting average with eight stolen bases and 13 runs scored thus far).

The Screaming Psychopaths also received Jed Lowrie, Rajai Davis and Jonathan Broxton.  Lowrie is by no means a replacement for Cano, but he is certainly serviceable at second base.  Lowrie had a career season in 2013 and has followed it up nicely (.296 batting average, two home runs, 10 RBI, 17 runs scored through April 26).  In fact, those numbers currently trump Cano’s output (.290 batting average, one home run, 10 RBI, nine runs scored).  Granted, Cano will unquestionably out-produce Lowrie, but the point to establish is that there is a respectable replacement included in the deal.

Rajai Davis will form a an impactful combination with Ellsbury in terms of scoring runs and stealing bases.  Davis has been playing more frequently and regularly than expected when he signed with Detroit.  His .353 batting average and eight stolen bases are a nice complement to the deal.

Finally, Jonathan Broxton has turned the clock back and is unscathed thus far in 2014.  He has filled in admirably for Aroldis Chapman as closer for the Reds and converted four saves without being scored upon yet.  He will likely relinquish his closing duties once Chapman returns, so this acquisition will likely only have short-term benefits from a saves category perspective.

In Pursuit of the Grail has broken up arguably the CAFBL’s best outfield and now corners the market on second baseman with the acquisition of Cano.  He now has both Jason Kipnis and Cano, one of which will likely serve as a Middle Infielder.  Starling Marte has struggled this year (.244 batting average and striking out over 33% of the time), but he does possess the speed to be able to steal as many bases as Ellsbury.  He also gave up Broxton who is his only relief pitcher.  Considering that Broxton won’t be closing when Chapman returns, it seems as though In Pursuit of the Grail is essentially punting the saves category to pursue other improvements.

This star-studded deal makes sense from both teams’ perspectives.  See Los Pollos Hermanos vs. Little Stumps, 3 F.J. 192, 195 (October 2011) (holding that 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).  The two packages of players present fair and equitable value.  Based on the foregoing, the Court approves the trade between In Pursuit of the Grail and the Screaming Psychopaths.

IT IS SO ORDERED.

 

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