Coming From Behind vs. 2015 is My Year – 6 F.J. 365 (July 14, 2014) – Fantasy Baseball Trade Review (F.Hernandez/R.Braun/J.Cueto)

SUPREME COURT OF FANTASY JUDGMENT

Coming From Behind vs. 2015 is My Year

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

Decided July 14, 2014
Cite as 6 F.J. 365 (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

This is now the seventh version of a trade between these two teams after three previously proposed deals were rejected by the Court.  Coming From Behind vs. Miggy is Back, 6 F.J. 250 (June 12, 2014) (rejecting the trade of Gregory Polanco, Yangervis Solarte, Yovani Gallardo, and Rick Porcello in exchange for Ryan Braun, Jhonny Peralta, Felix Hernandez and Trevor Rosenthal); Coming From Behind vs. Miggy is Back, 6 F.J. 258 (June 15, 2014) (rejecting the trade of Gregory Polanco, Yangervis Solarte, John Lackey and Rick Porcello in exchange for Ryan Braun, Andrelton Simmons, Felix Hernandez and Trevor Rosenthal); Coming From Behind vs. 2015 is My Year, 6 F.J. 264 (June 20, 2015) (rejecting the trade of Rick Porcello and Michael Wacha in exchange for Felix Hernandez and Trevor Rosenthal); Coming From Behind vs. 2015 is My Year, 6 F.J. 274 (June 21, 2014) (rejecting the trade of Yangervis Solarte and Gregory Polanco in exchange for Ryan Braun and Andrelton Simmons); Coming From Behind vs. 2015 is My Year, 6 F.J. 290 (June 24, 2015) (rejecting the trade of Gregory Polanco and Yangervis Solarte in exchange for Ryan Braun); Coming From Behind vs. 2015 is My Year, 6 F.J. 302 (June 28, 2014) (rejecting the trade of Gregory Polanco, Yangervis Solarte, Yovani Gallardo, Michael Wacha and John Lackey in exchange for Ryan Braun, Felix Hernandez and Trevor Rosenthal).

The trade now being submitted to the Court is as follows: Coming From Behind traded Michael Wacha (SP-STL, $7.00 salary in 2014), Michael Morse (OF-SF, $1.00 salary in 2014) and Johnny Cueto (SP-CIN, $11.00 salary in 2014) to 2015 is My Year in exchange for Ryan Braun (OF-MIL, $38.00 salary in 2014) and Felix Hernandez (SP-SEA, $29.00 salary in 2014).

Issue Presented

(1)   Should the amended deal between Coming From Behind and 2015 is My Year be approved?

Decision

After the Court previously rejected the prior six trades between these teams, Coming From Behind and 2015 is My Year agreed to another amended trade which is now subject for approval.  We incorporate by reference the Court’s past decisions in this lineage of cases.

As we have discussed before, 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).

We again acknowledge that this deal epitomizes the keeper league trade strategy dichotomy where one team is employing a “win now” mentality and the other team has conceded the current season and is building towards the future.  But under the CAFBL’s rules, we must primarily consider the overall impact of this trade on the current season.

Typically the Court would set its own guidelines and standards for evaluating the merits of a trade if one is not provided by the league.  However, the CAFBL does have its own set of written rules which we must defer to.  As important as it is to follow the language of the league’s rules, it is equally as important to understand the theory and rationale that exist behind each rule.  See A New Hope vs. On the Juice, 1 F.J. 4, 7 (September 2009).  It is apparent that the CAFBL seeks to maintain competitive balance during the current season by preventing lopsided dump trades.  We don’t infer that the CAFBL wants to prevent keeper trades, but rather the league wants to ensure that the present is given just as much priority as the future.  Right, wrong, or indifferent, those are the rules of the league for the 2014 season and we must adjudicate within those parameters.

Ryan Braun and Felix Hernandez have repeatedly been determined to have elite status which means we have a higher level of scrutiny when analyzing whether fair and equitable compensation is being exchanged for them.  Up until now, each package of compensation has failed to provide the requisite present day value necessary to comport with the CAFBL’s rules.  After six previously failed attempts, these two teams have finally reached an agreement that the Court considers equitable in compliance with the rules.

Braun is a better player than Michael Morse, but Morse’s numbers (.271 with 14 home runs and 46 RBI) compare well to Braun (.298 with 11 home runs and 52 RBI) and are likely going to be strikingly similar with respect to power and run production by the end of the season.  Similarly, Johnny Cueto (10-6 with a 2.13 ERA, 0.89 WHIP, and 141 strikeouts) is also a fantasy ace despite not being quite at the level of Felix Hernandez (11-2 with a 2.12 ERA, 0.90 WHIP, and 154 strikeouts).  To help make up the slight difference in value, 2015 is My Year also acquires Michael Wacha who is one of best young pitchers in baseball.  He is currently on the disabled list and it is unknown when he may return.  But assuming he is able to come back at some point in August, he will greatly improve the depth of his pitching staff this year and beyond.

Despite the fact that elite players were not traded back for Braun and Hernandez, the compensation provided by Coming From Behind is fair and equitable based on current statistics, projected value for the rest of the season, and it does not undermine the integrity of the league with respect to present day value.  Based on the foregoing, the Court approves this amended trade between Coming From Behind and 2015 is My Year.

IT IS SO ORDERED.

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