In Pursuit of the Grail vs. 2015 is My Year – 6 F.J. 347 (July 13, 2014) – Fantasy Baseball Trade Review (J.Verlander/J.Lester/J.Weaver)

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. 347 (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 Jon Lester (OF-BOS, $7.00 salary in 2014), Alcides Escobar (SS-KC, $2.00 salary in 2014) and Lucas Duda (1B-NYM, $5.00 salary in 2014) to 2015 is My Year in exchange for Justin Verlander (SP-DET, $27.00 salary in 2014), Jered Weaver (SP-LAA, $13.00 salary in 2014), Trevor Rosenthal (RP-STL, $3.00 salary in 2014), Jhonny Peralta (SS-STL, $2.00 salary in 2014) and Denard Span (OF-WAS, $5.00 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 Jon Lester, Alcides Escobar and Lucas Duda in exchange for Justin Verlander, Jered Weaver, Trevor Rosenthal, Jhonny Peralta and Denard Span looks fair and equitable.  None of the players involved in this deal are 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).  Verlander’s inconsistency and ongoing struggles have removed him from elite status.  However, he is still a top fantast pitcher with the capability of turning things around and dominating as he has done before.  In addition, Lester has great peripheral numbers but has not reached elite status as of now due to fluctuation in his statistics from year to year.

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).

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, the biggest difference in value seems to be quantity rather than quality.  In Pursuit of the Grail has obtained five players including three pitchers whereas 2015 is My Year only received three totals players including one pitcher.  However, that one pitcher acquired by 2015 is My Year is Jon Lester who has been outstanding thus far in 2014.  Despite only having nine wins, Lester has a sparkling 2.65 ERA, 1.13 WHIP, and a K/BB ratio of 134/29 in 129 innings.  His win total has been affected by poor run support and a shaky bullpen.  At only $7.00 in salary, Lester provides tremendous value for both this season and the future.

In terms of the three pitchers going to In Pursuit of the Grail, it is a mixed bag.  Both Justin Verlander and Jered Weaver were elite pitchers not too long ago, but things have changed.  They both are still valuable but nowhere near where they were in the past.  Trevor Rosenthal is a valuable closer because he pitches for St. Louis and gets a lot of opportunities.  While he does have 28 saves, his peripheral numbers are not great with a 3.50 ERA and 1.37 WHIP.

Recognizing that trading Jon Lester for Verlander, Weaver and Rosenthal is not the sole component of this deal, we acknowledge that the comparison is at least reasonable despite the quantity being exchanged.  We would have to give the edge to In Pursuit of the Grail simply because he is receiving three pitchers, including a closer, for Lester.  But that advantage is not disparate enough by itself to render this trade inequitable.  In addition, the exchange of offensive players is unquestionably equitable.  Lucas Duda and Alcides Escobar present fair compensation for Jhonny Peralta and Denard Span.  Both packages provide a mix of power and speed at various positions, and their combined salaries are identical at $7.00.

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 conclude that this trade is fair and equitable within the confines of the rules.  Based on the foregoing, the Court approves the subject trade between In Pursuit of the Grail and 2015 is My Year.

IT IS SO ORDERED.

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