Miggy is Back vs. Screaming Psychopaths – 6 F.J. 153 (May 21, 2014) – Fantasy Baseball Trade Review (R.Braun/W.Rosario/J.Werth)

SUPREME COURT OF FANTASY JUDGMENT

Miggy is Back vs. Screaming Psychopaths

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

Decided May 21, 2014
Cite as 6 F.J. 153 (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

Miggy is Back traded Michael Cuddyer (OF-COL, $14.00 salary in 2014), Wilin Rosario (C-COL, $16.00 salary in 2014) and Jayson Werth (OF-WAS, $15.00 salary in 2014) to the Screaming Psychopaths in exchange for Ryan Braun (OF-MIL, $38.00 salary in 2014), Jackie Bradley, Jr. (OF-BOS, $1.00 salary in 2014), Yan Gomes (C-CLE, $3.00 salary in 2014) and Joe Nathan (RP-DET, $13.00 salary in 2014)

Issue Presented

(1)   Should the trade between Miggy is Back 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 Michael Cuddyer, Wilin Rosario, and Jayson Werth in exchange for Ryan Braun, Jackie Bradley, Jr., Yan Gomes and Joe Nathan looks fair and equitable.  Braun is considered an elite player 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).  The Court has no issues with the idea of trading a superstar player so long as the package in return is equitable and makes sense given the needs of both teams.  See 4 Ponies vs. Beaver Hunters, 3 F.J. 26, 29 (June 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).

Braun is the central figure in this deal given his previous statistical production.  However, there are inherent risks associated with having him on a fantasy roster right now.  Throughout the first eight weeks of the 2014 season, Braun has dealt with injuries to his thumb and oblique, both of which have cost him a few weeks of games.  In addition, he is of course coming back from a 65-game suspension for PED’s.  There is obvious and understandable doubt whether he can sustain similar statistical production presumably without the aid or benefit of PED’s.  Despite all of these concerns, the fact remains that Braun is still one of the best hitters in baseball and deserves to remain considered an elite player (with a current batting average of .294 along with seven home runs, 19 RBI, 19 runs scored and three stolen bases in only 30 games).

The Screaming Psychopaths certainly have enough outfield depth to trade Braun away.  They still have Carlos Gonzalez, Jacoby Ellsbury and Dominic Brown, along with the new acquisitions of Michael Cuddyer and Jayson Werth.  In fact, Cuddyer and Werth combined more than make up for Braun’s production and provide the Screaming Psychopaths with even more surplus and depth in their outfield.

In addition to having outfield depth, the Screaming Psychopaths have an incredible surplus of closers so trading away Joe Nathan should not have any detrimental effect on their position in the saves category.  They still have Sergio Romo, Kenley Jansen, Aroldis Chapman, Mark Melancon and Casey Janssen.

The trade serves to provide the Screaming Psychopaths with a significant upgrade at catcher as they obtained Wilin Rosario in exchange for Yan Gomes.  Rosario has emerged as one of the best offensive catchers in baseball which makes him extremely valuable to GM’s in fantasy leagues.  He averaged just under 25 home runs, 75 RBI, and a .280 batting average from 2012-2013 which makes him one of the premier fantasy options in the entire league.

Miggy is Back clearly is looking to make a splash by acquiring a superstar like Braun.  This does come with some risk because he essentially has very little in outfield talent aside from Braun on his roster.  But that is a personal and strategic decision made by a GM who is entitled to manage his team accordingly.  While Miggy is Back does suffer a downgrade at catcher, he did acquire Joe Nathan to help him ascend the saves category.

This 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).  While Braun is the only player considered elite in this trade, the compensation being exchanged for him is fair and equitable.  The deal provides upgrades to both teams at different positions and demonstrates both of their respective interests and priorities.  Based on the foregoing, the Court approves the trade between Miggy is Back and the Screaming Psychopaths.

IT IS SO ORDERED.

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