Moneymakers vs. Stritz-4-U – 6 F.J. 157 (May 22, 2014) – Fantasy Baseball Trade Review (M.Trout/M.Harvey/A.McCutchen)

SUPREME COURT OF FANTASY JUDGMENT

Moneymakers vs. Stritz-4-U

ON PETITION FOR WRIT OF CERTIORARI FROM
THE JABRONI LEAGUE

Decided May 22, 2014
Cite as 6 F.J. 157 (May 2014)

Factual Background

A rotisserie fantasy baseball league called the Jabroni League (hereinafter referred to as “JL” was established in 1999 and is hosted on CBS.  The JL is a 12-team mixed AL/NL keeper league where teams are permitted to maintain a maximum of six (6) players.  GM’s can either retain players under a one-year contract or a three-year contract.  If a player was acquired during the auction draft, his value escalates $5.00 the following season.  If a player was acquired via free agency, his value escalates $8.00 the following season and then $5.00 every subsequent year capped at three years of keeper eligibility.

The JL uses a standard 5×5 format for its 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.

All trades made between GM’s are subject to review.  Due to the fact that the JL is comprised of several clusters of family members and close relatives, the commissioner has the sole authority to submit all trades to the Court for review to avoid any potential conflicts.

The commissioner has submitted a trade to the Court for review to determine whether it should be approved or rejected.

Procedural History

The Moneymakers traded Andrew McCutchen (OF-PIT) and Justin Upton (OF-ATL) to Stritz-4-U in exchange for Mike Trout (OF-LAA, can be kept for $18.00 in 2015), Matt Harvey (SP-NYM, can be kept for $6.00 in 2015) and Mookie Betts (2B-BOS, can be kept for $8.00 in 2015).

Issue Presented

(1)   Should the trade between the Moneymakers and Stritz-4-U 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 JL 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 Andrew McCutchen and Justin Upton in exchange for Mike Trout, Matt Harvey, and Mookie Betts looks fair and equitable.  Several players in this deal are considered elite for purposes of requiring additional scrutiny merely because of how valuable they are.  Steelers vs. Patriots, 3 F.J. 216, 220 (November 2011).   Trout and McCutchen are unquestionably two of the top ten fantasy players in any format.  Harvey had elite status in 2013 prior to sustaining an elbow injury which necessitated Tommy John surgery.  He is on track to return in 2015, so assuming he has no setbacks he can be afforded the benefit of the doubt and retain elite status in a keeper league.

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).

The Court can surmise that the Moneymakers are taking the approach that epitomizes the thought process for GM’s in a keeper league that no longer have any hope for contending in the current season.  He/she must make critical roster management decisions of whether to trade off established players in exchange for less expensive entities in building for the future.  See Winners vs. Seven Shades of Shite, 3 F.J. at 102.

Despite the fact that it is only Week 8 of the fantasy baseball season and we have not even reached Memorial Day, it is still within the Moneymakers’ discretion to make the realistic determination of his own team’s fate for the rest of the season.  See Victoria’s Secret vs. NY Cowboys, 6 F.J. 149, 151 (May 2014).  By virtue of making this trade with Stritz-4-U, the dichotomy of keeper league trade strategy has been exemplified given the competing interests of one team in a “win now” mentality coupled with a trade partner looking to build for the future by trading away expensive assets.  Knights vs. Seawolves, 5 F.J. 46, 48 (May 2013).

The combination of both McCutchen and Upton provides Stritz-4-U with two tremendously talented outfielders who can provide solid production in all five roto categories.  Despite trading away an elite player like Mike Trout, Stritz-4-U will more than make up for his departure with the combined statistical production of McCutchen and Upton.

On the other hand, the Moneymakers are looking more long-term with this trade.  Despite the fact that Mike Trout has a lingering hamstring injury and is only batting .270 with eight home runs, 31 RBI, 29 runs scored and five stolen bases, he is still arguably the second best fantasy player in a Roto format.  It should be fully expected that he will provide elite production for the rest of the season and into 2015.

In addition to Trout, the Moneymakers have also acquired Matt Harvey who is currently rehabbing after undergoing Tommy John surgery in late 2013.  Although he wants to return to the big leagues later this season, the Mets have indicated that he will not come back until 2015.  Assuming he does not suffer any setbacks and can build up his arm strength and endurance through next spring training, the Moneymakers will have obtained a fantasy ace for their pitching staff in 2015.

Finally, the Moneymakers also acquired Red Sox Double-A prospect Mookie Betts.  Betts has torn up Double-A pitching and has also started playing all three outfield positions.  His natural position is second base which is currently occupied by Dustin Pedroia.  With all of Boston’s offensive problems and injuries woes in their outfield, Betts could reach the big leagues sooner rather than later by being able to play the outfield.  He is certainly part of a long-term plan for the Moneymakers.

Even without knowing the teams’ rosters, this deal appears to make 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).  This star-studded trade demonstrates the differing and competing interests of teams heading in different directions in a keeper league.  While McCutchen and Upton are an incredible package of talent, the compensation exchanged for them has fair and equitable value in terms of both present and future value.  Based on the foregoing, the Court approves the trade between the Moneymakers and Stritz-4-U.

IT IS SO ORDERED.

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