4 Ponies vs. Kramer Dogs – 6 F.J. 229 (June 4, 2014) – Fantasy Baseball Trade Review (J.Garcia/T.Thornburg)

SUPREME COURT OF FANTASY JUDGMENT

4 Ponies vs. Kramer Dogs

ON PETITION FOR WRIT OF CERTIORARI FROM
THE INCONTINENT LEAGUE

Decided June 4, 2014
Cite as 6 F.J. 229 (June 2014)

Factual Background

A rotisserie fantasy baseball league called The Incontinent League (hereinafter referred to as “roto league” or “IL” is a 12-team NL-only keeper league utilizing an auction-style draft and transaction platform.  Teams are permitted to maintain up to ten (10) players during each off-season with individual players allowed to be kept for a maximum of three (3) consecutive years under contract.  Each team is also permitted to keep two minor league players which are in addition to the ten players kept.  This roto league also has a $26.00 draft salary cap, as well as a $36.00 in-season salary cap that is applicable for all teams.

As with many rotisserie leagues, the Incontinent League 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.  Statistics are cumulative throughout the course of the season and there are no head to head games contained within the Roto league.

The Incontinent League’s commissioner submitted a proposed trade between two league members and seeks an opinion on whether the trade should be approved.

Procedural History

The 4 Ponies traded Jaime Garcia (SP-STL, $1.00 in the first year of his existing contract with two years remaining) and Joe Kelly (SP-STL, $1.00 in the second year of his existing contract with one year remaining) to the Kramer Dogs in exchange for Tyler Thornburg (RP-MIL, $1.00 in the first year of his existing contract with two years remaining) and Tommy LaStella (2B-ATL, $0.50 and can be kept at that salary for three years).

Issue Presented

(1)   Should the trade between the 4 Ponies and the Kramer Dogs 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 IL 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 Jaime Garcia and Joe Kelly in exchange for Tyler Thornburg and Tommy LaStella looks fair and equitable.  None of the players involved in this deal are considered elite for purposes of requiring additional scrutiny merely because of his inherent value and statistical production.  See Steelers vs. Patriots, 3 F.J. 216, 220 (November 2011).

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).

The Kramer Dogs are currently in 4th place and in need of wins to help ascend the standings.  Neither Garcia nor Kelly are overpowering and will not contribute much in terms of strikeouts.  But they both should be in line for wins so long as they can stay healthy.  The Cardinals have the fortune of having both a good offense and a solid bullpen (despite some struggles by closer Trevor Rosenthal).  In general, St. Louis starting pitchers are valuable fantasy commodities because they can accumulate wins even without having solid peripheral statistics.

The 4 Ponies are currently in 10th place, although this trade cannot be considered one synonymous with conceding the current season and playing for the future.  Tyler Thornburg has been an effective middle reliever for Milwaukee with solid overall numbers.  It is also possible that he can still become a starter down the road or next year.  In addition, Tommy LaStella was recently promoted and could be in line for significant playing time at second base with the Braves.

The trade makes sense from both GM’s perspectives and satisfies their respective goals based on the composition of their rosters and where they are heading in the standings.  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).  The compensation being exchanged for each other is unquestionably fair and equitable.  Based on the foregoing, the Court approves the trade between the 4 Ponies and the Kramer Dogs.

IT IS SO ORDERED.

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