Lil Nicky vs. Moneymakers – 6 F.J. 241 (June 8, 2014) – Fantasy Baseball Trade Review (J.Hamilton/B.Gardner)

SUPREME COURT OF FANTASY JUDGMENT

Lil Nicky vs. Moneymakers

ON PETITION FOR WRIT OF CERTIORARI FROM
THE JABRONI LEAGUE

Decided June 8, 2014
Cite as 6 F.J. 241 (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

Lil Nicky traded Josh Hamilton (OF-LAA, can be kept for $23.00 in 2015) to the Moneymakers in exchange for Brett Gardner (OF-NYY, can be kept for $8.00 in 2015).

Issue Presented

(1)   Should the trade between Lil Nicky 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 Brett Gardner in exchange for Josh Hamilton looks slightly inequitable.  Neither player in this deal is 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).

When a trade such as this is consummated involving the exchange of players at the same position, it can reasonably be inferred that neither team has a specific positional need to improve upon.  Rather, we can surmise that the two trading partners are either more interested in the players’ particular skill sets or the factors of a keeper league trade are in play.  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 Moneymakers just recently acquired Brett Gardner in a previous trade.  See Diamond Kutters vs. Moneymakers, 6 F.J. 222 (June 3, 2014).  While Gardner is certainly a valuable player to keep at only $8.00, the Moneymakers are flipping him for Josh Hamilton who is clearly a better offensive player when healthy.  Hamilton’s numbers are eschewed because he spent almost two months on the disabled list with a torn ligament in his thumb.  But all things being equal, Hamilton is a superior hitter to Gardner in terms of power and run production.  If those are categories that the Moneymakers are prioritizing, then they are certainly well within their rights to pursue improvement.

Gardner represents fair and equitable value to Lil Nicky despite not having the same propensity for home runs and RBI.  Rather, Gardner contributes more in the other three categories with batting average, runs scored and stolen bases.  He has solidified himself as an everyday player in the Yankees lineup and is signed for the next four years in New York.  From a keeper league perspective, this is good news for Lil Nicky especially since Gardner is $15.00 less expensive than Hamilton.

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).  Even without knowing these teams’ rosters, we can surmise that both the Moneymakers and Lil Nicky have different and competing priorities in terms of the composition of their teams.  While Hamilton provides better power and run production, Gardner is more productive in the other categories and provides Lil Nicky with salary cap flexibility.  Based on the foregoing, the Court approves the trade between Lil Nicky and the Moneymakers.

IT IS SO ORDERED.

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