Mister Salty vs. The Danger Zone – 6 F.J. 322 (July 3, 2014) – Fantasy Baseball Trade Review (R.Zimmerman/B.Phillips/H.Kendrick)

SUPREME COURT OF FANTASY JUDGMENT

Mister Salty vs. The Danger Zone

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

Decided July 3, 2014
Cite as 6 F.J. 322 (July 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

Mister Salty traded and Joe Nathan (RP-DET, $13.00 salary in 2014), Alejandro De Aza (OF-CHW, $5.00 salary in 2014) and Howie Kendrick (2B-LAA, $5.00 salary in 2014) to the Danger Zone in exchange for Ryan Zimmerman (3B-WAS, $31.00 salary in 2014) and Brandon Phillips (2B-CIN, $15.00 salary in 2014),.

Issue Presented

(1)   Should the trade between Mister Salty and the Danger Zone 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 Alejandro De Aza, Howie Kendrick and Joe Nathan in exchange for Ryan Zimmerman and Brandon Phillips looks fair and equitable in terms of present day value.  None of the players involved in this trade 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).

Mister Salty is continuing his pursuit of success during the current season by acquiring veteran players such as Ryan Zimmerman and Brandon Phillips.  Both players still have value, but they have been trending downwards due to age and injuries.  Phillips was once one of the top second baseman in fantasy baseball due to his combination of power and speed.  But over the past few years, his stolen base totals have dropped off dramatically including this year when he only has one thus far.  As of the present date, Phillips is batting .260 with seven home runs and 37 RBI which is respectable, but a far cry from he used to produce.  In fact, Phillips has finished with 18 home runs each of the past four seasons.  He should reach that mark again barring injury.

Ryan Zimmerman is a shell of his former self thanks in large part to injuries.  He has had perpetual shoulder problems the past few years which prompted a temporary shift into the outfield.  His shoulder issues have also affected his offense as he is only batting .253 with three home runs and 21 RBI.  He will not come close to replicating the statistics he has had the past few years of 25+ home runs and average over 80 RBI.  There is always a concern for his health, so he is a risky investment.

The package being traded back to the Danger Zone appears fair and equitable.  Howie Kendrick is certainly sufficient compensation for Brandon Phillips as he is batting .272 with four home runs and 34 RBI along with 46 runs scored and 10 stolen bases.  Kendrick likely won’t have the same power output as Phillips, but he is equal to and better in all other categories.  Plus, he is younger and less expensive than Phillips and could be a better keeper option for the Danger Zone.

As we have stated before, Joe Nathan is a marginal closer at this point in his career.  He does have 17 saves, but his ERA and WHIP are category-busters.  See Mister Salty vs. Lame Duck Psychopaths, 6 F.J. 318 (July 2014).  That being said, he should still accumulate several more saves this year as the Tigers’ closer.

The final piece of the package is Alejandro De Aza who usually does not play against left-handed pitchers.  De Aza has struggled this season compiling only a .228 batting with five home runs and 25 RBI.  However, he does have 12 stolen bases which are valuable in and of itself.  With Dayan Viciedo struggling even more than him, De Aza could see an increase in playing time during the second half of the season.

When looking at the overall packages being exchanged, Mister Salty is certainly receiving players with better resumes and more pronounced name recognition.  But the fact remains that both Phillips and Zimmerman are not worth what they once were.  The combination of Nathan, Kendrick and De Aza is fair and equitable compensation for the former stars.  The deal satisfies the needs and motivations of both teams, and the present day value of the deal does not undermine the integrity of the league based on the current season.  Based on the foregoing, the Court approves the subject trade between Mister Salty and the Danger Zone.

IT IS SO ORDERED.

 

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