Glutton for Punishment vs. Rebuilding Again – 6 F.J. 29 (March 21, 2014) – Fantasy Baseball Trade Review (B.Gardner/D.Ackley)

SUPREME COURT OF FANTASY JUDGMENT

Glutton for Punishment vs. Rebuilding Again

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

Decided March 21, 2014
Cite as 6 F.J. 29 (March 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

Glutton for Punishment traded Brett Gardner (OF-NYY, $7.00 salary in 2014) to Rebuilding Again in exchange for Melky Cabrera (OF-TOR, $2.00 salary in 2014) and Dustin Ackley (OF-SEA, $2.00 salary in 2014).

Issue Presented

(1)   Should the trade between Glutton for Punishment and Rebuilding Again 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 Brett Gardner in exchange for Melky Cabrera and Dustin Ackley looks fair and equitable.  None of the players involved in this deal are considered elite for purposes of requiring additional scrutiny merely because of how valuable they are based on their statistics and name recognition  See Steelers vs. Patriots, 3 F.J. 216, 220 (November 2011).

This trade involves three outfielders, so presumably neither team had a specific positional need when negotiating the deal.  However, there are specific goals that both GM’s had in consummating this trade.  Brett Gardner is the most valuable player in the trade primarily because of his stolen bases.  Gardner just signed a four-year contract extension with the Yankees which means he will be playing mostly every day in a lineup where he should easily score 100 runs.  After having injuries in 2012 and 2013, it is expected that Gardner will reach stolen base levels akin to 2010 and 2011 (47 and 49 respectively).

It makes sense that Rebuilding Again would want Gardner paired up with Everth Cabrera to compete in the steals category.  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).

After reviewing Glutton for Punishment’s roster, it is apparent that his outfield is shallow in terms of quality and depth.  While Gardner is a better player, he was able to acquire two outfielders who will likely be in his starting lineup.  Cabrera is coming off an injury-plagued season and is now looking to re-establish his value two seasons after his drug suspension.  Ackley came on strong in the second half of 2013 and increased his value by gaining OF eligibility.  With all of the moves the Mariners made, he should still see plenty of playing time.

This deal makes 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).  Based on the foregoing, the Court approves the trade between Glutton for Punishment and Rebuilding Again.

IT IS SO ORDERED.

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