Coming From Behind vs. Miggy is Back – 6 F.J. 250 (June 12, 2014) – Fantasy Baseball Trade Rejected (F.Hernandez/R.Braun/G.Polanco)

SUPREME COURT OF FANTASY JUDGMENT

Coming From Behind vs. Miggy is Back

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

Decided June 12, 2014
Cite as 6 F.J. 250 (June 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

Coming From Behind traded Gregory Polanco (OF-PIT, $3.00 salary in 2014), Yangervis Solarte (3B-NYY, $5.00 salary in 2014), Yovani Gallardo (SP-MIL, $3.00 salary in 2014) and Rick Porcello (SP-DET, $3.00 salary in 2014) to Miggy is Back in exchange for Ryan Braun (OF-MIL, $38.00 salary in 2014), Jhonny Peralta (SS-STL, $2.00 salary in 2014), Felix Hernandez (SP-SEA, $29.00 salary in 2014) and Trevor Rosenthal (RP-STL, $3.00 salary in 2014),

Issue Presented

(1)   Should the trade between Coming From Behind and Miggy is Back 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 Gregory Polanco, Yangervis Solarte, Yovani Gallardo and Rick Porcello in exchange for Ryan Braun, Jhonny Peralta, Felix Hernandez and Trevor Rosenthal does not look fair and equitable.  Ryan Braun and Felix Hernandez 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).

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 Court can surmise that Miggy is Back is 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 11 of the fantasy baseball season, it is still within Miggy is Back’s 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).  In contrast, Coming From Behind is currently in first place in his division and is clearly employing a “win now” mentality.

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).  In addition, the CAFBL’s rules specifically prioritize evaluating the merits of a trade based on its impact during the current season.

When looking at the overall packages being exchanged, Miggy is Back clearly comes out on the short end of the stick in terms of present-day value.  Granted, they would be acquiring Gregory Polanco who is one of the top prospects in the baseball and was just promoted to the Pirates this week.  But it is unreasonable to expect or project him to produce statistics equivalent or comparable to Ryan Braun in 2014.  In terms of the infielders in this trade, we find that Peralta and Solarte have comparable value albeit in different roto categories.

With respect to the pitchers involved in this trade, Coming From Behind gets the advantage by a wide margin.  Felix Hernandez is an elite player and easily one of the top fantasy baseball pitchers in the league.  He has consistently provided elite production in most categories for many years and is showing no signs of slowing down.  Now that the Mariners have an improved team, he is able to secure more wins than in recent years because poor run support and a bad bullpen cost him.

In conjunction with Hernandez, Coming From Behind is also obtaining Trevor Rosenthal who has become one of the better closers in baseball despite a rough patch earlier in 2014.  He emerged as the Cardinals closer during the 2013 playoffs and has already saved 17 games while averaging over one strikeout per inning.

In comparison to Hernandez and Rosenthal, Miggy is Back sustains a significant downgrade with the combination of Gallardo and Porcello.  We know comparing starters to relievers is akin to apples and oranges because it is more based on team needs and preferences.  But here, Hernandez by himself is much more valuable and productive than the combination of Gallardo and Porcello.  When you add a top closer like Rosenthal to the equation, the disparity becomes too great to overlook.

By making this trade, Miggy is Back would essentially be saving $58.00 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 present day value and quality of the packages being exchanged for each other.  We understand what Miggy is Back trying to do, but the windfall obtained by Coming From Behind is too great to ignore.  Given the CAFBL’s specific rules on trade evaluation, we cannot conclude that there is fair and equitable value being exchanged.  Based on the foregoing, the Court rejects the subject trade between Coming From Behind and Miggy is Back.

IT IS SO ORDERED.

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