Diamond Kutters vs. Moneymakers – 6 F.J. 206 (May 26, 2014) – Fantasy Baseball Trade Rejected (J.Votto/J.Samardzija/M.Minor)

SUPREME COURT OF FANTASY JUDGMENT

Diamond Kutters vs. Moneymakers

ON PETITION FOR WRIT OF CERTIORARI FROM
THE JABRONI LEAGUE

Decided May 26, 2014
Cite as 6 F.J. 206 (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 Diamond Kutters traded Joey Votto (1B-CIN, can be kept for $42.00 in 2015), Hyun-Jin Ryu (SP-LAD, can be kept for $16.00 in 2015), and Mike Minor (SP-ATL, cannot be kept in 2015) to the Moneymakers in exchange for Anthony Rendon (2B/3B-WAS, can be kept for $7.00 in 2015), Mookie Betts (2B-BOS, can be kept for $8.00 in 2015) and Jeff Samardzija (SP-CHC, can be kept for $14.00 in 2015).

Issue Presented

(1)   Should the trade between the Diamond Kutters and the Moneymakers 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 Joey Votto, Hyun-Jin Ryu, and Mike Minor in exchange for Anthony Rendon, Jeff Samardzija, and Mookie Betts looks inequitable.  None of the 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).   The Court acknowledges that Votto was once regarded as elite, but multiple seasons of underperforming and some recent injuries have removed him from having elite status.  Diamond Kutters vs. Ballbusters, 6 F.J. 183, 184 (May 2014).

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 Diamond Kutters 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 9 of the fantasy baseball season, it is still within the Diamond Kutters’ 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).  Based on some previous trades made by the Diamond Kutters, it is apparent that they are essentially having a fire sale and trading away some of their most valuable and expensive assets in the hopes of building for the future.

The motivations of both teams seem readily apparent and in good faith.  However, a trade of this magnitude must be looked at very closely to ensure its present-day inequity does not go against the spirit of the league.  That is because lopsided trades can throw off the competitive balance of a league and create a slippery slope for future trades.  The Court has no issues with the idea of trading star players 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 looking at the overall packages being exchanged, the Diamond Kutters clearly come out on the short end of the stick in terms of present-day value.  Granted, they were going to lose Mike Minor back to the draft regardless, so the Court understands why the Diamond Kutters would want to obtain some form of compensation for him rather than lose him for nothing.  Besides that, the deal does not improve the Diamond Kutters in any aspect looking at it from both present day and long-term perspectives.

By making this trade, the Diamond Kutters would essentially be saving $29.00 in salary cap money assuming all players were kept at their projected values.  This is a significant amount of salary cap money, but that does not in and of itself make the trade equitable.  While obtaining salary cap flexibility in a keeper is league is one of the many objectives teams have for making trades to rebuild for the future, its benefits can be trumped by the inequitability of the current players being traded away.  Beaver Hunters vs. 4 Ponies, 4 F.J. 129, 131 (July 2012).  That is what appears to be the case here.

White it is normally acceptable for teams in keeper leagues to make trades that do not have equivalent present-day value, a deal that is so completely lopsided and goes against the best interests of the league will be rejected.  See Smittydogs vs. Moneyball, 4 F.J. 57 (May 2012) (rejecting a trade of Ryan Braun and Edwin Jackson in exchange for Randall Delgado, Dee Gordon and Bobby Abreu); Team Sabo vs. 4 Ponies, 4 F.J. 50 (May 2012) (rejecting a trade of Joey Votto and Tyler Clippard in exchange for Drew Stubbs, Francisco Rodriguez and Starling Marte).  The subject trade is lopsided in terms of the value and quality of the packages being exchanged for each other.  We understand what the Diamond Kutters are trying to do, but the windfall obtained by the Moneymakers is too great to ignore.

This trade is distinctive from one of the Diamond Kutters previous trades when they dealt away David Wright, Yu Darvish and Craig Kimbrel.  See Diamond Kutters vs. Buena Vista Social Club, 6 F.J. 165 (May 2014).  In that deal, the level of talent they traded away was arguably greater than in the subject deal.  However, the compensation that the Diamond Kutters obtained was much more equitable in value (the Diamond Kutters received Aroldis Chapman, Oscar Taveras, and Yordano Ventura which provided significant present day and long-term value).

In fact, this trade is similar to the one we previously ruled on in Diamond Kutters vs. Ballbusters, 6 F.J. 183, 184 (May 2014) (rejecting the trade of Brett Gardner, Joey Votto, Alex Cobb, Hyun-Jin Ryu and Kurt Suzuki in exchange for Shane Victorino, Charlie Blackmon, Wellington Castillo, Bronson Arroyo, and Travis Wood).  In this trade, the disparity in the present-day value of the packages is too great to ignore.  While Mookie Betts is a highly-regarded prospect, he does not provide enough future value to compensate for the difference in value that the Moneymakers are receiving.  Despite the fact that Votto is currently injured and has seen his power numbers decrease over the past couple seasons, he is still a far superior player to Rendon.  In addition, Samardzija has become a viable fantasy pitcher but he is still winless despite pitching so well.  His accomplishments and value alone is not enough to be considered equitable for the combination of both Ryu and Minor.  We understand that Minor is just a short-term investment since he cannot be kept in 2015, but he has great value for the remainder of the current season.

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.  See Los Pollos Hermanos vs. Little Stumps, 3 F.J. 192, 195 (October 2011); see also Speedboys vs. Kramerdogs, 5 F.J. 109 (July 2013) (rejecting a trade of Paul Goldschmidt, Adam Wainwright and Rafael Soriano in exchange for Bryce Harper, A.J. Burnett Trevor Rosenthal, and Archie Bradley).  The Court concludes that the compensation being provided by the Moneymakers fails to provide sufficient discernible benefit to the Diamond Kutters, either in present day or future value.  There is such a disparity between the values of the packages that the motivations for rebuilding are not enough to warrant approval of this deal.  Based on the foregoing, the Court rejects the trade between the Diamond Kutters and the Moneymakers.

IT IS SO ORDERED.

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