Beaver Hunters vs. Speedboys – 6 F.J. 339 (July 10, 2014) – Fantasy Baseball Trade Rejected (B.Hamilton/B.Harper/J.Papelbon)

SUPREME COURT OF FANTASY JUDGMENT

Beaver Hunters vs. Speedboys

ON PETITION FOR WRIT OF CERTIORARI FROM
THE INCONTINENT LEAGUE

Decided July 10, 2014
Cite as 6 F.J. 339 (July 2014)

Factual Background

A rotisserie fantasy baseball league called The Incontinent League (hereinafter referred to as “roto league” or “IL” is a 12-team NL-only keeper league utilizing an auction-style draft and transaction platform.  Teams are permitted to maintain up to ten (10) players during each off-season with individual players allowed to be kept for a maximum of three (3) consecutive years under contract.  Each team is also permitted to keep two minor league players which are in addition to the ten players kept.  This roto league also has a $26.00 draft salary cap, as well as a $36.00 in-season salary cap that is applicable for all teams.

As with many rotisserie leagues, the Incontinent League 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.  Statistics are cumulative throughout the course of the season and there are no head to head games contained within the Roto league.

The Incontinent League’s commissioner submitted a proposed trade between two league members and seeks an opinion on whether the trade should be approved.

Procedural History

The Beaver Hunters traded Billy Hamilton (OF-CIN, $0.50 in the first year of his existing contract with two years remaining), Hyun-Jin Ryu (SP-LAD, $1.40 in the second year of his existing contract with one year remaining), Jonathan Papelbon (RP-PHI, $1.80 in the first year of his existing contract with two years remaining), Jordy Mercer (2B-PIT, $1.00 in the first year of his existing contract with two years remaining) and Tim Stauffer (SP-SD, $1.00 in the first year of his existing contract with two years remaining) to the Speedboys in exchange for Bryce Harper (OF-WAS, $0.50 in the final year of his existing contract), Matt Carpenter (2B/3B-STL, $1.00 in the final year of his contract), Lance Lynn (SP-STL, $0.40 in the final year of his existing contract), Trevor Rosenthal (RP-STL, $1.00 in the final year of his existing contract), and Gio Gonzalez (SP-WAS, $2.30 in the final year of his existing contract).

Issue Presented

(1)   Should the trade between the Beaver Hunters and the Speedboys 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 IL 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 Billy Hamilton, Hyun-Jin Ryu, Jonathan Papelbon, Jordy Mercer and Tim Stauffer in exchange for Bryce Harper, Matt Carpenter, Lance Lynn, Trevor Rosenthal and Gio Gonzalez looks completely inequitable.  None of the players in this trade are considered elite for purposes of requiring additional scrutiny merely because of his inherent value and statistical production.  See Steelers vs. Patriots, 3 F.J. 216, 220 (November 2011).  However, there are still several valuable stars included in the deal that require sufficient compensation in order to be traded.

Typically the only circumstances where we will reject a trade are: 1) if the deal is made in violation of league rules; 2) if the deal is made through collusion; 3) the deal is so grossly lopsided that is has a detrimental effect on the whole league; and 4) if the deal makes absolutely no sense and/or fails to improve at least one of the team’s rosters in any capacity.  Grand Theft Votto vs. That Wimpy Deer, 6 F.J. 39, 42 (April 2014).  In this case, only numbers 3 and 4 are at issue.

Without considering the contract status and salaries of the players involved, this trade is so completely imbalanced that is does not even pass the initial sniff test which would at least lead to a statistical comparison and analysis.  See Tiger’s Blood vs. Hulkamaniacs, 3 F.J. 58, 60 (July 2011).  There is no empirical data that could demonstrate how this trade has equitable compensation being exchanged.  It would be a waste of judicial economy to engage in such analysis at this time.

We acknowledge that the Speedboys were going to lose Harper, Carpenter, Lynn, Rosenthal and Gonzalez at the end of the season anyway since their contracts were expiring.  Rather than lose them for nothing, the Speedboys wisely sought compensation for those players now.  While the Court has no issues with the idea of trading star players, we must ensure that 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).

It is normally acceptable for teams in keeper leagues to make trades that do not have equivalent present-day value because one party to the trade is usually pursuing future value or building towards next season.  However, a deal that is so completely lopsided and goes against the best interests of the league will be rejected.  See Smittydogs vs. Moneyball, 4 F.J. 57 (May 2012) (rejecting a trade of Ryan Braun and Edwin Jackson in exchange for Randall Delgado, Dee Gordon and Bobby Abreu); Team Sabo vs. 4 Ponies, 4 F.J. 50 (May 2012) (rejecting a trade of Joey Votto and Tyler Clippard in exchange for Drew Stubbs, Francisco Rodriguez and Starling Marte).

There is no question that the package being dealt to the Beaver Hunters is far superior to that which is being obtained by the Speedboys.  In fact, some of the vocal complaints by fellow league GM’s is that the Beaver Hunters did not even have to trade away Gregory Polanco or Michael Wacha in order to consummate this deal.  Those are the type of players that are typically included as compensation in dump trades such as this.  Granted, GM’s are not obligated to shop players around for a more advantageous deal solely to appease skeptical league members.  See Road Runners vs. Urban Achievers, 3 F.J. 47, 50 (June 2011).  But it is undeniable that insufficient compensation is being provided for the caliber of players that the Beaver Hunters are acquiring.

This trade does fall square within the dichotomy of keeper league trade strategy which is exemplified when one team in contention has a “win now” mentality and acquires more expensive players who may not be under contract following the season.  The other party is a GM who is building for the future by selling off assets.  Knights vs. Seawolves, 5 F.J. 46, 48 (May 2013).  But that does not give GM’s carte blanche to negotiate lopsided deals which could have a detrimental effect on the integrity of the league during the current season.

The Beaver Hunters are in 2nd place and clearly are making a run at a league championship this year.  On the other hand, the Speedboys are currently in 8th place and have conceded the current season.  The inequity of a trade consummated in a keeper league can be exacerbated by the fact it is being made between teams at polar opposite ends of the standings.  That is not to say teams at the top and bottom of the standings cannot or should not make trades with each other.  But when deals are made that do not have equitable value or conceivably benefit the team lower in the standings, it creates more of a perception of impropriety and unevenly affects the balance of power in the league.  Beaver Hunters vs. 4 Ponies, 4 F.J. 129, 131 (July 2012).

Billy Hamilton is the only player in the deal with any significant value for the Speedboys.  While he would be under contract for the next two years, that does not equate to the value of what he traded away even though those five players are all re-entering the draft in 2015.  Recall that each GM can keep up to ten players per season.  Hamilton is certainly a keeper, but the other players acquired (with the possible exception of Ryu) are not candidates to be kept.  Jordy Mercer is a light-hitting middle infielder without a permanent job or position on Pittsburgh.  Tim Stauffer has seemingly been around forever with San Diego and is nothing more than a mediocre pitcher who has shifted between starting and relieving during the few years he has been healthy.  Jonathan Papelbon is having a tremendous year, but there is a good possibility he will be traded by the Phillies given that he has indicated he would waive his no-trade clause to go to a contender.[1]  If in fact he is traded to an American League team, then he is rendered useless in the IL.  As a result, Papelbon has significant risk attached to him because of the specter of a potential trade by Philadelphia.

As previously mentioned, the Court has no issues with the Speedboys trading away players with expiring contracts.  However, the compensation proposed here is far from equitable.  The disparity in present day value is so great that the integrity of the league could be jeopardized.  Additionally, Billy Hamilton’s future value is not significant enough to balance out the inequity that exists in this deal.  Based on the foregoing, the Court rejects the trade between the Beaver Hunters and the Speedboys.  We recommend attempting to modify the trade with other assets that are available on the Beaver Hunters’ roster in order to properly balance out the deal.

IT IS SO ORDERED.

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