Buena Vista vs. Blue Monsters – 6 F.J. 336 (July 8, 2014) – Fantasy Baseball Trade Review (J.Abreu/P.Goldschmidt/M.Bumgarner)

SUPREME COURT OF FANTASY JUDGMENT

Buena Vista vs. Blue Monsters

ON PETITION FOR WRIT OF CERTIORARI FROM
THE JABRONI LEAGUE

Decided July 8, 2014
Cite as 6 F.J. 336 (July 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

Buena Vista traded Jose Abreu (1B-CHW, can be kept for $18.00 in 2015), Yovani Gallardo (SP-MIL, can be kept for $6.00 in 2015) and Dylan Bundy (SP-BAL) to the Blue Monsters in exchange for Paul Goldschmidt (1B-ARZ, cannot be kept in 2015), Hunter Pence (OF-SF, can be kept for $34.00 in 2015) and Madison Bumgarner (SP-SF, can be kept for $34.00 in 2015).

Issue Presented

(1)   Should the trade between Buena Vista and the Blue Monsters 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 Jose Abreu, Yovani Gallardo and Dylan Bundy in exchange for Paul Goldschmidt, Hunter Pence and Madison Bumgarner fair and equitable.  There are several players involved in this trade that are considered elite for purposes of requiring additional scrutiny merely because of how valuable they are.  Steelers vs. Patriots, 3 F.J. 216, 220 (November 2011).  Paul Goldschmidt (.312 with 16 home runs, 59 RBI, 66 runs scored and eight stolen bases) has emerged as one of the top overall fantasy players and is a legitimate top five overall pick.. Madison Bumgarner (9-6 with a 3.08 ERA, 1.19 WHIP and 120 strikeouts) is a premier starting pitcher who is arguably the second best left-handed starter behind Clayton Kershaw.  Finally, Jose Abreu (.275 with 27 home runs and 69 RBI) has quickly burst on the scene and is leading all of baseball in home runs during his rookie season despite missing a couple weeks with an injury.

When a trade such as this is consummated involving the exchange of players at all 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 record is devoid of any information regarding where either of these teams are in the standings.  However, we can surmise that Buena Vista is employing a “win now” mentality by making this deal.  They are trading away a rising star in Abreu and replacing him with Goldschmidt whose contract will expire at the end of the season.  In addition, they are dealing away a top pitching prospect in Dylan Bundy.  The collective acquisitions of Goldschmidt, Pence and Bumgarner strongly indicates that Buena Vista is pursuing a championship this season.

On the other hand, the Blue Monsters were going to lose Goldschmidt at the end of the season anyway.  It makes perfect sense that they would want to obtain some form of compensation for him rather than lose him for nothing.  Getting back Abreu in the deal is great value for the Blue Monsters as he has quickly become one of the premier power hitters in baseball.

The Court does not have any information regarding the composition of either teams’ rosters.  However, we can reasonably conclude that the combination of Pence and Bumgarner is far more valuable than the combination of Gallardo and Bundy based on present day value.  Bumgarner is already an established elite pitcher, and Pence provides solid and consistent production in all five categories.  On the other hand, Gallardo is a mid-range fantasy pitcher who has rebounded from a bad 2013 but is akin to a roster filler.  Bundy is recovering from major arm surgery and could be called up by the Orioles before the end of the season.  However, realistically Bundy won’t contribute much until 2015 when he is another year removed from the operation and can have a normal spring training.

Even without knowing their rosters or the current standings, this deal appears to make 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).  This star-studded trade is filled with elite players, but the compensation being exchanged is fair and equitable.  In addition, the deal also falls in line with the dichotomy of keeper league trade strategy.  Based on the foregoing, the Court approves the trade between Buena Vista and the Blue Monsters.

IT IS SO ORDERED.

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