Logan’s Heroes vs. Buena Vista Baseball Club – 6 F.J. 255 (June 13, 2014) – Fantasy Baseball Trade Review (J.Fernandez/C.Hamels/J.Grilli)

SUPREME COURT OF FANTASY JUDGMENT

Logan’s Heroes vs. Buena Vista Baseball Club

ON PETITION FOR WRIT OF CERTIORARI FROM
THE JABRONI LEAGUE

Decided June 13, 2014
Cite as 6 F.J. 255 (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

Logan’s Heroes traded Jason Grilli (RP-PIT, cannot be kept in 2015) and Cole Hamels (SP-PHI, can be kept for $17.00 in 2015) to the Buena Vista Baseball Club in exchange for Jose Fernandez (SP-MIA., must be kept for $13.00 in 2015 and $18.00 in 2016), Tyler Skaggs (SP-LAA, can be kept for $8.00 in 2015) and Jacob deGromm (SP-NYM, can be kept for $8.00 in 2015).

Issue Presented

(1)   Should the trade between Logan’s Heroes and the Buena Vista Baseball Club 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 Jason Grilli and Cole Hamels in exchange for Jose Fernandez, Tyler Skaggs and Jacob deGromm looks inequitable based on present day value.  Fernandez was on track towards being considered elite for purposes of requiring additional scrutiny merely because of how valuable he is.  Steelers vs. Patriots, 3 F.J. 216, 220 (November 2011).   However, he has undergone Tommy John surgery and will miss the rest of 2014 and likely part of 2015.  As such, he is not regarded as elite, nor is any other player in this deal.

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.  But when a deal includes the exchange of a starting pitcher for a closer, it can reasonably be concluded that both GM’s have different interests and priorities with respect to the composition of their rosters.  See Posey’s Posse vs. That Wimpy Deer, 6 F.J. 61, 62 (April 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).

This trade epitomizes the dichotomy of motivations that exist in a keeper league.  Knights vs. Seawolves, 5 F.J. 46, 48 (May 2013) (holding that he dichotomy of keeper league trade strategy is exemplified when one team in contention has a “win now” mentality by acquiring more expensive players who may not be under contract following the season, coupled with a trade partner who building for the future by selling off assets).  The record is devoid of where these two teams are in the standings and what the composition of their respective rosters is.  However, we can surmise that Logan’s Heroes have are giving up on the current season and building for the future.  The Court reaches that conclusion based on the fact that Grilli cannot be kept next year and Logan’s Heroes wisely is looking to obtain some form of tangible compensation for him rather than lose Grilli for nothing.  In addition, Logan’s Heroes is acquiring Jose Fernandez who is currently out for the year after having Tommy John surgery.  This is clearly a move with foresight in mind as Fernandez likely won’t be back until sometime during the 2015 season.

On the other hand, the Buena Vista Baseball Club appears to be employing a “win now” mentality by trading away three young, talented and relatively inexpensive pitchers in exchange for established players like Grilli and Hamels.  As we previously mentioned, Grilli’s contract expires at the end of the season so he is merely a rental.  Hamels is a well-established pitcher who will provide more stability and consistency than the younger and less experienced Skaggs and deGromm.

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, both GM’s motivation behind this keeper league trade is apparent.  There is also sufficient long-term value being provided by Logan’s Heroes to offset the disparity in present day value.  Based on the foregoing, the Court approves the trade between Logan’s Heroes and the Buena Vista Baseball Club.

IT IS SO ORDERED.

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