Bill & Suzie’s Tavern vs. Carson City Cocks – 6 F.J. 129 (May 6, 2014) – Fantasy Baseball Trade Review (A.Wood/K.Jansen)

SUPREME COURT OF FANTASY JUDGMENT

Bill & Suzie’s Tavern vs. Carson City Cocks

ON PETITION FOR WRIT OF CERTIORARI FROM
THE INCONTINENT LEAGUE

Decided May 6, 2014
Cite as 6 F.J. 129 (May 2014)

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

Bill & Suzie’s Tavern traded Alex Wood (SP-ATL, $1.00 in the second year of his contract with one year remaining) to the Carson City Cocks in exchange for Kenley Jansen (RP-LAD, $2.80 in the first year of his contract with two years remaining).

Issue Presented

(1)   Should the trade between Bill & Suzie’s Tavern and the Carson City Cocks 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 IL 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).

At first glance, the trade of Alex Wood in exchange for Kenley Jansen looks fair and equitable.  Neither player involved in this trade is considered elite for purposes of requiring additional scrutiny merely because of their inherent value or projected statistical production.  See Steelers vs. Patriots, 3 F.J. 216, 220 (November 2011).

When a trade such as this is consummated involving the exchange of a starting pitcher for a closer, it can reasonably be concluded that both GM’s have different interests and priorities with respect to the composition of their rosters.  See Posey’s Posse vs. That Wimpy Deer, 6 F.J. 61 (April 2014) (approving a trade of Garrett Richards for Kenley Jansen).  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).

Bill & Suzie’s Tavern are currently in 5th place but second to last in the saves category.  They have tremendous starting pitching, especially with Clayton Kershaw set to return and join a pitching staff that also includes Adam Wainwright, Johnny Cueto and Mike Minor.  Bill & Suzie’s Tavern can afford to trade away Alex Wood and his unfortunate 2-5 record.  Despite that poor win-loss record which is due in large part to poor run support and bullpen failures, Wood has been extremely reliable with a 3.00 ERA, 1.17 WHIP, and has averaged just under one strikeout per inning through his first seven starts.  This is a classic example of a fantasy GM trading from a surplus in order to address another need.

The Carson City Cocks are currently in 9th place and in need of an upgrade at starting pitching.  Prior to this deal, their most reliable starting pitchers consisted of Nathan Eovaldi, Francisco Liriano and Charlie Morton.  While Jansen’s 11 saves have helped the Carson City Cocks share 5th place in that category, he has uncharacteristically been a detriment in both ERA (3.52) and WHIP (1.63).  The Carson City Cocks also have Aroldis Chapman on their roster who will be returning shortly to replace Jansen’s saves.[1]  Rather than try to move up in the saves category with multiple closers, the Carson City Cocks are making a strategic roster decision for which categories to pursue improvement.  They also obtain $1.80 in salary cap relief which can be used to make further acquisitions later in the season in their continued efforts to ascend the standings.

Both pitchers in this trade have their own intrinsic value and satisfy the respective needs of both teams.  The 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).  Based on the foregoing, the Court approves the trade between Bill & Suzie’s Tavern and the Carson City Cocks.

IT IS SO ORDERED.

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