The Mudhen Wannabe’s vs. Blood Moon – 6 F.J. 132 (May 9, 2014) – Fantasy Baseball Trade Review (D.Jeter/A.Guerrero)

SUPREME COURT OF FANTASY JUDGMENT

The Mudhen Wannabe’s vs. Blood Moon

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

Decided May 9, 2014
Cite as 6 F.J. 132 (May 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

The Mudhen Wannabe’s traded Alex Guerrero (2B-LAD, $4.00 salary in 2014) to Blood Moon (formerly known as the Screaming Psychopaths) in exchange for Derek Jeter (SS-NYY, $3.00 salary in 2014)

Issue Presented

(1)   Should the trade between the Mudhen Wannabe’s and Blood Moon 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 Alex Guerrero in exchange for Derek Jeter looks fair and equitable.  Neither player involved in this trade is considered elite for purposes of requiring additional scrutiny merely because of how valuable they are  See Steelers vs. Patriots, 3 F.J. 216, 220 (November 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).

This trade represents competing interests for both teams.  Alex Guerrero is a top prospect in the Dodgers’ organization that can provide long-term value.  On the other hand, Derek Jeter is retiring after the 2014 season so he obviously has no long-term value.  Rather, his only value is for the remainder of this season in which he is currently batting .261 with one home run, seven RBI, and eight runs scored.  After missing almost all of 2013 with injuries, Jeter appears healthy.  However, his productivity is marginalized because of his age, the wear and tear on his body, and the fact he will be given sufficient rest throughout the course of the season.

Since we have to look mostly at how this trade affects these teams during the current season, we must analyze whether Guerrero’s potential impact when he is promoted is equitable to Jeter’s minimal production.  The Court believes it is equitable.  It is unknown when Guerrero will be promoted as he was injured for awhile in the minor leagues and is now learning how to play second base.  Even when or if he is promoted, it is arguable that he will have a period of adjustment getting used to major league pitching.  The immediate success of Yasiel Puig in 2013 cannot be used as a benchmark for a rookie player.

Blood Moon previously acquired Jed Lowrie in a trade, so they could afford to give up Jeter without suffering at shortstop.  See In Pursuit of the Grail vs. Screaming Psychopaths, 6 F.J. 103 (April 2014).  It is just as questionable whether Jeter can maintain his health for the duration of the season, and he clearly is not the same hitter he was as recently as 2012.  If Guerrero is ultimately promoted and does not produce, or even if he remains in the minor leagues all season, Blood Moon is not losing out on significant production by trading away Jeter.

This trade epitomizes the dichotomy of GM’s strategies in a keeper league to either build for the future or sacrifice future assets for present-day upgrades.  Knights vs. Seawolves, 5 F.J. 46, 48 (May 2013).  The value being exchanged does not create any imbalance or inequity in terms of the current season which is one of the main criteria for evaluating trades in the CAFBL.  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 the Mudhen Wannabe’s and Blue Moon.

IT IS SO ORDERED.

 

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