Bay of Puigs vs. Lame Duck Psychopaths – 6 F.J. 373 (July 14, 2014) – Fantasy Baseball Trade Rejected (A.Gonzalez/M.Franco/J.Singleton)

SUPREME COURT OF FANTASY JUDGMENT

Bay of Puigs vs. Lame Duck Psychopaths

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

Decided July 14, 2014
Cite as 6 F.J. 373 (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

Bay of Puigs traded Maikel Franco (3B-PHI, $2.00 salary in 2014), Jon Singleton (1B-HOU, $1.00 salary in 2014) and Eugenio Suarez (SS-DET, $5.00 salary in 2014) to the Lame Duck Psychopaths in exchange for Adrian Gonzalez (1B-LAD, $28.00 salary in 2014), Adam LaRoche (1B-WAS, $5.00 salary in 2014) and Drew Storen (RP-WAS, $5.00 salary in 2014).

Issue Presented

(1)   Should the trade between the Bay of Puigs and Lame Duck Psychopaths 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 Maikel Franco, Jon Singleton and Eugenio Suarez in exchange for Adrian Gonzalez, Adam LaRoche and Drew Storen does not look equitable in terms of present day value.  None of the players involved in this deal are considered elite for purposes of requiring additional scrutiny merely because of how valuable they are.  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 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 Lame Duck Psychopaths have continually been taking the approach that epitomizes the thought process for GM’s in a keeper league that no longer have 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.  On the other hand, the Grumpy Grumpires are 9.5 games out of first place but only two games out of third place in his division.  They are clearly employing a “win now” mentality by making this deal.

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.

This trade does not provide the Lame Duck Psychopaths with much present day value at all.  Jon Singleton has become an everyday player since being called up by the Astros, but he is only batting .183 with 57 strikeouts in 136 at bats.  He does have six home runs and 21 RBI, but it is clear that he is overmatched by big league pitching to this point.  Eugenio Suarez has become the Tigers starting shortstop but does not provide much in terms of offensive production.  To date, Suarez is batting .265 with three home runs and 11 RBI.  Finally, Maikel Franco is currently at Triple-A and it does not look like he will be called up by the Phillies any time soon.

The package of Singleton, Suarez and Franco is a solid foundation to build on for the future.  But as we previously stated, they are unlikely going to produce much for the rest of 2014.  As we know, the CAFBL’s rules require the Court to primary consider the integrity and competitiveness of the trade based on its impact during the current season. When compared to the package of Adrian Gonzalez, Adam LaRoche and Drew Storen, the difference is significant.

Gonzalez is a consistently solid first baseman with strong power numbers and usually a productive batting average.  Currently he is batting .250 with 14 home runs and 60 RBI.  In addition, Adam LaRoche has similar numbers to Gonzalez compiling a .278 batting average along with 12 home runs and 47 RBI.  While those are not spectacular numbers, they are far superior to what has been produced and what is projected for Singleton for the rest of the year.  Finally, Drew Storen has been dominant in his role as a setup relief pitcher with a 1.20 ERA and 0.90 WHIP.

When looking at the overall packages being exchanged, the present day value is not equitable.  The Lame Duck Psychopaths will not receive much, if anything, in terms of value for 2014. This is especially true when compared to what they are trading away.  The package of Gonzalez, LaRoche and Storen is hardly elite, but they can be counted on for what they produce.  Under the confines of the league’s rules, we must conclude that the disparity in present day value is too significant despite the obvious keeper league intentions of the parties.  Based on the foregoing, the Court rejects the subject trade between the Bay of Puigs and the Lame Duck Psychopaths.

IT IS SO ORDERED.

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