Kalamunda Rangers vs. Moneymakers – 6 F.J. 216 (June 2, 2014) – Fantasy Baseball Trade Review (M.Trout/R.Braun/C.Davis)

SUPREME COURT OF FANTASY JUDGMENT

Kalamunda Rangers vs. Moneymakers

ON PETITION FOR WRIT OF CERTIORARI FROM
THE JABRONI LEAGUE

Decided June 2, 2014
Cite as 6 F.J. 216 (June 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 Kalamunda Rangers traded Kalamunda Rangers Ryan Braun (OF-MIL, can be kept for $39.00 in 2015), Chris Davis (1B-BAL, can be kept for $40.00 in 2015) and Stephen Strasburg (SP-WAS, can be kept for $23.00 in 2015) to the Moneymakers in exchange for Mike Trout (OF-LAA, can be kept for $18.00 in 2015), Hyun-Jin Ryu (SP-LAD, can be kept for $16.00 in 2015) and Matt Harvey (SP-NYM, can be kept for $6.00 in 2015).

Issue Presented

(1)   Should the trade between the Kalamunda Rangers 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 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 Braun, Davis and Strasburg in exchange for Trout, Ryu and Harvey looks slightly uneven.  Braun, Davis and Trout are all 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 does not have an issue with trading superstar players so long as the compensation being exchanged for them is equitable.  Strasburg and Harvey are two of the most talented young pitchers in baseball, but at this point they cannot be considered elite.

When a trade such as this is consummated involving the exchange of players at 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).

Since the record is devoid of any information regarding where either of these teams are in the standings, we can only draw inferences from the trade itself on whether the dichotomy of keeper league trade strategy is being employed.  Knights vs. Seawolves, 5 F.J. 46, 48 (May 2013) (holding that keeper leagues tend to demonstrate a dichotomy in trade strategy where one team is in a “win now” mentality coupled with a trade partner looking to build for the future by trading away expensive assets).  We previously surmised that the Kalamunda Rangers were looking to build for the future based on a prior trade they made.  Kalamunda Rangers vs. Stritz-4-U, 6 F.J. 213 (June 2014) (where the Kalamunda Rangers traded Josh Donaldson and his expiring contract in exchange for George Springer and Dellin Betances).  It appears that they are furthering this strategy by entering into this trade which nets them $60.00 in salary cap relief.

Braun and Davis are two of the best power hitters in the league despite the fact they have both endured injuries this season.  Collectively their power and run production is far superior to Mike Trout who is the only offensive player being sent to the Kalamunda Rangers.  But Trout is one of the few players in the league who contributes significantly in all five Roto categories and costs significantly less than both Braun and Davis.  It should be noted that Trout has suffered from both hamstring and back problems this year, and his stolen base attempts and totals have decreased due to a more prominent presence in the middle of the Angels lineup.  It is not unreasonable to predict that this trend will continue.

In terms of the pitchers being traded, the biggest wild card is Matt Harvey who will miss the entire 2014 season as he recovers from Tommy John surgery.  All indications are that he will be ready for spring training in 2015 barring any setbacks.  If he can regain his form from 2013, then he can be one of the most dominant pitchers in the league at a very modest salary of $6.00.  The Kalamunda Rangers are also acquiring Hyun-Jin Ryu who has also been reliable and productive since making his debut in 2013.  While Stephen Strasburg is dynamic (3.14 ERA and 90 strikeouts), the combination of Harvey and Ryu is more than equitable.

The Moneymakers are clearly employing a “win now” mentality by acquiring the expensive contracts of Braun and Davis.  This strategy is also furthered with the acquisition of Strasburg while trading away the currently injured Matt Harvey.  Even without knowing their rosters or the current standings, 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).  While the deal clearly favors the Moneymakers based on present-day value, the compensation exchanged is equitable pursuant to a keeper league evaluation.  Based on the foregoing, the Court approves the trade between the Kalamunda Rangers and the Moneymakers.

IT IS SO ORDERED.

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