Rebuilding Again vs. Screaming Psychopaths – 6 F.J. 187 (May 25, 2014) – Fantasy Baseball Trade Review (C.Davis/A.Pujols/D.Bundy)

SUPREME COURT OF FANTASY JUDGMENT

Rebuilding Again vs. Screaming Psychopaths

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

Decided May 25, 2014
Cite as 6 F.J. 187 (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

Rebuilding Again traded Chris Davis (1B-BAL, $7.00 salary in 2014), Mark Teixeira (1B-NYY, $8.00 salary in 2014) and Dylan Bundy (SP-BAL, $1.00 salary in 2014) to the Screaming Psychopaths in exchange for Albert Pujols (1B-LAA, $30.00 salary in 2014), Martin Prado (3B-ARZ, $15.00 salary in 2014), Michael Cuddyer (OF-COL, $14.00 salary in 2014), Sergio Romo (RP-SF, $12.00 salary in 2014) and Aroldis Chapman (RP-CIN, $9.00 salary in 2014).

Issue Presented

(1)   Should the trade between Rebuilding Again 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 Chris Davis, Mark Teixeira, and Dylan Bundy in exchange for Albert Pujols, Martin Prado, Michael Cuddyer, Sergio Romo and Aroldis Chapman looks slightly inequitable.  None of the players in this deal are 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).  However, this deal is littered with multiple star players on both sides.

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 Screaming Psychopaths are continuing to take 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.  Through previous trades, it seems apparent that the Screaming Psychopaths, currently in second to last place in their division, are building towards the future.  That motive appears to be furthered by making the subject trade.

Despite the fact that it is only the end of Week 8 of the fantasy baseball season and we have not even reached Memorial Day, it is still within the Screaming Psychopaths’ 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 Rebuilding Again, 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).

Under the CAFBL’s rules, we must analyze this trade from the perspective of how it will affect the current season as opposed to the bigger picture.  On its face, it appears that both teams will obtain benefits for the current season.  However, it cannot be denied that Rebuilding Again obtained a distinct advantage with the acquisitions of closers Sergio Romo and Aroldis Chapman while the Screaming Psychopaths will not likely get much, if any, production  from Dylan Bundy in 2014.  Bundy is one of the top pitching prospects in baseball, but he is attempting to come back after having surgery in 2013.  It is not known when or if Bundy will be promoted to the Orioles at some point later in the season.

From an offensive standpoint, the Screaming Psychopaths fared well by trading away three expensive contracts in Pujols, Cuddyer and Prado and got significant power and run production back in Davis and Teixeira.  Davis and Teixeira’s combined salary is $15.00 while the opposite trio is a combined $59.00.  This is a significant saving in salary cap space, especially for the type of production that has been produced and is expected to be provided from these players.

Overall, the Screaming Psychopaths will net $64.00 in salary cap space from this deal.  That is a tremendous amount of financial flexibility to have  which will allow them to make further moves and lock up their own players long-term.  While they have continued to deplete their surplus of closers by dealing away Romo and Chapman, the fact remains that they still do have Kenley Jansen, Mark Melancon (who will have limited opportunities with Jason Grilli back), and Hector Rondon.  They can at least remain competitive in the saves category and used their depth and surplus to acquire one of the top young pitching prospects in baseball.

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).  Both teams furthered their respective goals, and the difference in present day value of the packages is minimal enough to pass muster under the CAFBL’s rules.  Based on the foregoing, the Court approves the trade between Rebuilding Again and the Screaming Psychopaths.

IT IS SO ORDERED.

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