Coming From Behind vs. 2015 is My Year – 6 F.J. 302 (June 28, 2014) – Fantasy Baseball Trade Rejected (F.Hernandez/R.Braun/G.Polanco)

SUPREME COURT OF FANTASY JUDGMENT

Coming From Behind vs. 2015 is My Year

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

Decided June 28, 2014
Cite as 6 F.J. 302 (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

This is now the sixth version of a trade between these two teams after three previously proposed deals were rejected by the Court.  Coming From Behind vs. Miggy is Back, 6 F.J. 250 (June 12, 2014) (rejecting the trade of Gregory Polanco, Yangervis Solarte, Yovani Gallardo, and Rick Porcello in exchange for Ryan Braun, Jhonny Peralta, Felix Hernandez and Trevor Rosenthal); Coming From Behind vs. Miggy is Back, 6 F.J. 258 (June 15, 2014) (rejecting the trade of Gregory Polanco, Yangervis Solarte, John Lackey and Rick Porcello in exchange for Ryan Braun, Andrelton Simmons, Felix Hernandez and Trevor Rosenthal); Coming From Behind vs. 2015 is My Year, 6 F.J. 264 (June 20, 2015) (rejecting the trade of Rick Porcello and Michael Wacha in exchange for Felix Hernandez and Trevor Rosenthal); Coming From Behind vs. 2015 is My Year, 6 F.J. 274 (June 21, 2014) (rejecting the trade of Yangervis Solarte and Gregory Polanco in exchange for Ryan Braun and Andrelton Simmons); Coming From Behind vs. 2015 is My Year, 6 F.J. 290 (June 24, 2015) (rejecting the trade of Gregory Polanco and Yangervis Solarte in exchange for Ryan Braun).

The trade being submitted to the Court now is as follows: 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), Michael Wacha (SP-STL, $7.00 salary in 2014) and John Lackey (SP-BOS, $2.00 salary in 2014) to 2015 is My Year (formerly known as Miggy is Back) in exchange for Ryan Braun (OF-MIL, $38.00 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 amended deal between Coming From Behind and 2015 is My Year be approved?

Decision

After the Court previously rejected the prior five trades between these teams, Coming From Behind and 2015 is My Year agreed to another amended trade which is now subject for approval.  We incorporate by reference the Court’s past decisions in this lineage of cases.

As we have discussed before, 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).

We again acknowledge that this deal epitomizes the keeper league trade strategy dichotomy where one team is employing a “win now” mentality and the other team has conceded the current season and is building towards the future.  Gregory Polanco is one of the best prospects in baseball and certainly provides long-term value for 2015 is My Year.  But under the CAFBL’s rules, we must primarily consider the overall impact of this trade on the current season.

Typically the Court would set its own guidelines and standards for evaluating the merits of a trade if one is not provided by the league.  However, the CAFBL does have its own set of written rules which we must defer to.  As important as it is to follow the language of the league’s rules, it is equally as important to understand the theory and rationale that exist behind each rule.  See A New Hope vs. On the Juice, 1 F.J. 4, 7 (September 2009).  It is apparent that the CAFBL seeks to maintain competitive balance during the current season by preventing lopsided dump trades.  We don’t infer that the CAFBL wants to prevent keeper trades, but rather the league wants to ensure that the present is given just as much priority as the future.  Right, wrong, or indifferent, those are the rules of the league for the 2014 season and we must adjudicate within those parameters.

Ryan Braun has been struggling and battled a variety of injuries throughout the season.  Understandably, there are questions about his productivity after he was suspended for 65 games in 2013 for use of PED’s.  But the fact remains that Braun is still considered a superstar player with five-category roto production.  In addition, Felix Hernandez is unquestionably considered elite and is one of the top pitchers in all of fantasy baseball (9-2 with a 2.24 ERA, 0.94 WHIP, and 128 strikeouts in 120.1 innings).  The final piece of the package being offered by 2015 is My Year is Trevor Rosenthal who is still a top closer despite having early season struggles which inflated his ERA and WHIP.  Despite those struggles, he still has 24 saves and should have no problem reaching at least 40 by the end of the season.  We must determine whether sufficiently equitable present-day compensation is being exchanged for a group of this caliber.  Looking at the package of Gregory Polanco, Yangervis Solarte, Yovani Gallardo, Michael Wacha and John Lackey, the Court concludes once again that it has not.

The Court has no issues with the idea of trading superstar 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).  A player’s value is not necessarily equivalent to the accumulation of several other less valuable players’ statistics.  See Team Sabo vs. Nub Vader, 3 F.J. 55, 56 (July 2011).  What we have here appears to be an accumulation of players in an attempt to be considered equitable value for an elite package of players.

The first order of business is to eliminate Solarte from the equation.  As we have previously stated, Solarte earned a spot on the Yankees’ Opening Day roster with an impressive spring training and serious questions about the team’s incumbent infielders.  He was given an opportunity to play third base every day and was arguably the Yankees best hitter during April.  But as the season has progressed, Solarte has expectedly slowed down as pitchers adjusted to him.  Lately he has seen a decrease in his playing time and his current numbers (.266 with six home runs, 30 RBI, and 26 runs scored) are pedestrian at best.  Whatever value he had in April has dissipated drastically and at this point he is barely a viable option in deep mixed leagues/

Gregory Polanco is one of the best young outfielders in baseball and is certainly a valuable keeper league asset to acquire.  But we must primarily evaluate Polanco’s value in 2014 as opposed to the future in order to determine whether this trade passes muster.  While Polanco has hit well in his first 17 games (.319 with two home runs, ten RBI, 14 runs scored, and four stolen bases), the Court cannot conclude that a player with 72 career at bats provides sufficient compensation for Braun during the current season.

With respect to the pitchers involved in this deal, the Court acknowledges that statistically the difference between the two packages is not overly disparate.  Rosenthal is 2015 is My Year’s only closer so they are apparently punting the saves category.  They appear motivated to build a deeper pitching staff comprised of starters which is furthered by making this trade where they are obtaining Lackey, Wacha and Gallardo.  The Court has no issue whatsoever with what 2015 is My Year is attempting to do in this regard.  However, the difference in value of the overall packages in terms of the current season is too lopsided to ignore.

Lopsided trades throw off the competitive balance of the league and create a slippery slope for future trades.  This is precisely what the CAFBL is looking to prevent in its rules regarding the evaluation of trades.  Wacha (5-5 with a 2.79 ERA, 1.11 WHIP, and 83 strikeouts in 90.1 innings) is currently on the disabled list with a shoulder injury, so his contributions for the rest of 2014 are questionable.  Lackey (8-5 with a 3.44 ERA, 1.19 WHIP, and 93 strikeouts in 107 innings) and Gallardo (5-4 with a 3.22 ERA, 1.18 WHIP, and 77 strikeouts in 97.2 innings) are having decent seasons, but they pale in comparison to Hernandez.  It is true that the combination of Lackey, Wacha and Gallardo’s statistics may surpass those of Hernandez.  But allowing such cumulative trades of marginal players in exchange for elite players would undermine the integrity and competitive balance of the CAFBL during the current season.  Because this is expressly prohibited in the rules, we cannot allow that to happen.

The Court concedes that there is no collusion alleged and the motivations of both teams fall in line with the dichotomy of keeper league teams heading in opposite directions.  However, the CAFBL rules specifically emphasize the fairness and integrity of trades during the current season.  Despite these teams’ attempts to modify the trade, the compensation exchanged is still too disparate.  Coming From Behind would be receiving far greater value for the rest of this season and the difference in value does not comply with the CAFBL’s rules regarding maintaining competitiveness during the current season.  Based on the foregoing, the Court rejects this amended trade between Coming From Behind and 2015 is My Year.

IT IS SO ORDERED.

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