In Pursuit of the Grail vs. 2015 is My Year – 6 F.J. 343 (July 13, 2014) – Fantasy Baseball Trade Rejected (R.Braun/R.Davis/S.Marte)

SUPREME COURT OF FANTASY JUDGMENT

In Pursuit of the Grail vs. 2015 is My Year

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

Decided July 13, 2014
Cite as 6 F.J. 343 (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

In Pursuit of the Grail traded Starling Marte (OF-PIT, $11.00 salary in 2014) to 2015 is My Year in exchange for Ryan Braun (OF-MIL, $38.00 salary in 2014) and Rajai Davis (OF-DET, $7.00 salary in 2014).

Issue Presented

(1)   Should the trade between In Pursuit of the Grail and 2015 is My Year 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 Starling Marte in exchange for Ryan Braun and Rajai Davis does not look fair and equitable.  Despite his various injuries and the PED suspension in 2013, Braun is still considered elite for purposes of requiring additional scrutiny merely because of how valuable he is.  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 the same position, it can reasonably be concluded that neither GM has any specific positional need to fill and is rather looking to upgrade or improve at those positions.  See Stritz-4-U vs. Fire & Ice, 6 F.J. 271, 272 (June 20, 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).

2015 is My Year is in last place in his division and 23.5 games out of first place.  He is clearly taking the approach that epitomizes the thought process for GM’s in a keeper league that no longer has any hope for contending in the current season.  He/she must make critical roster management decisions of whether to trade off established players in exchange for less expensive entities in building for the future.  See Winners vs. Seven Shades of Shite, 3 F.J. at 102.

It is within 2015 is My Year’s discretion to make the realistic determination of his own team’s fate for the rest of the season.  See Victoria’s Secret vs. NY Cowboys, 6 F.J. 149, 151 (May 2014).  In contrast, In Pursuit of the Grail is currently in fourth place in his division and is clearly employing a “win now” mentality with these acquisitions.

The motivations of both teams seem readily apparent and in good faith.  However, a trade of this magnitude must be looked at very closely to ensure its present-day inequity does not go against the spirit of the league.  That is because lopsided trades can throw off the competitive balance of a league and create a slippery slope for future trades.  The Court has no issues with the idea of trading star 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).  In addition, the CAFBL’s rules specifically prioritize evaluating the merits of a trade based on its impact during the current season.

When looking at the overall packages being exchanged, 2015 is My Year clearly comes out on the short end of the stick in terms of present-day value.  Granted, they would be saving $34.00 in salary cap and space acquiring a young, talented outfielder in Marte.  But giving up both Braun and Davis represents an insurmountable downgrade for the rest of 2014.

Statistically, Marte (.256 with five home runs, 32 RBI, 40 runs scored and 21 stolen bases) and Davis (.287 with six home runs, 32 RBI, 36 runs scored, 24 stolen bases in 254 at bats.) are almost identical with Davis having a 30 point edge in batting average.  It would clearly be equitable compensation to trade these players straight up as they also have similar risks associated with them.  Marte has struggled mightily and has not shown any signs of being able to figure things out.  Davis was signed by the Tigers primarily to be a fourth outfielder, but due to injuries and opportunity he has played much more than expected.  He could see a decrease in at bats with the emergence of J.D. Martinez.

The question is whether the deal is still equitable when adding Ryan Braun along with Rajai Davis.  The answer is unequivocally in the negative.  Even though Braun has missed several games this year due to various injuries and has also had the specter of his PED suspension around him, he has still managed to hit .295 with 11 home runs, 50 RBI, 46 runs scored and eight stolen bases.  He is still an elite player, albeit with some inherent risks.  But combining him with Davis tips the balance so grossly with respect to the present day value of the players in this deal.

We must look at this deal from the perspective of how it affects the overall integrity and competitiveness of the league during this year.  That is because the CAFBL’s rules mandate it to be the primary consideration when evaluating trades.  Since it is a defined rule laid out by the league, the Court must defer to the rule and apply an analysis within those parameters.  Given this criteria, we can easily conclude that the combination of Ryan Braun and Rajai Davis is collectively far greater in value than Starling Marte.

By making this trade, 2015 is My Year would be saving $34.00 in salary cap money assuming all players were kept.  While obtaining salary cap flexibility in a keeper is league is one of the many objectives teams have for making trades to rebuild for the future, its benefits can be trumped by the inequitability of the current players being traded away.  Beaver Hunters vs. 4 Ponies, 4 F.J. 129, 131 (July 2012).  That is what appears to be the case here.

White it is normally acceptable for teams in keeper leagues to make trades that do not have equivalent present-day value, 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).  This trade is lopsided in terms of the present day value and quality of the packages being exchanged for each other.  We understand what 2015 is My Year is trying to do, but the windfall obtained by In Pursuit of the Grail is too great to ignore.  Given the CAFBL’s specific rules on trade evaluation, we cannot conclude that there is fair and equitable value being exchanged.  Based on the foregoing, the Court rejects the subject trade between In Pursuit of the Grail and 2015 is My Year.

IT IS SO ORDERED.

 

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