Mudhen Wannabe’s vs. Screaming Psychopaths – 6 F.J. 399 (July 21, 2014) – Fantasy Baseball Trade Review (C.Beltran/A.Gonzalez/M.Reynolds)

SUPREME COURT OF FANTASY JUDGMENT

Mudhen Wannabe’s vs. Screaming Psychopaths

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

Decided July 21, 2014
Cite as 6 F.J. 399 (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

The Mudhen Wannabe’s traded Carlos Beltran (OF-NYY, $13.00 salary in 2014) and Mark Reynolds (1B-MIL, $5.00 salary in 2014) to the Screaming Psychopaths in exchange for Adrian Gonzalez (1B-LAD, $28.00 salary in 2014) and Sam Fuld (OF-MIN, $5.00 salary in 2014).

Issue Presented

(1)   Should the trade between the Mudhen Wannabe’s and Screaming 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 Carlos Beltran and Mark Reynolds in exchange for Adrian Gonzalez and Sam Fuld looks fair and 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).

This trade represents an even exchange of a first baseman and an outfielder for both teams.  When a trade such as this is consummated involving the exchange of players at the same positions, it can reasonably be concluded that both GM’s do not have any specific positional needs to address.  Rather, they are seeking specific improvement in a particular category or have other keeper league strategies in mind.  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 Screaming 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 Mudhen Wannabe’s are in 3rd place and only 4.5 games out of first place.  They are clearly employing a “win now” mentality by making this deal.

Adrian Gonzalez has statistically been much better than Carlos Beltran thus far this year.  However, Gonzalez has slowed down significantly over the past two months and has seen his batting average drop to .250 along with 14 home runs and 60 RBI.  The reason this is alarming is because he has never hit below .277 during a full season in his career.  Beltran has missed significant time with various injuries to his knee, elbow and eye.  He now appears healthy and can be expected to increase his production.  Assuming both Gonzalez and Beltran remain healthy, they represent reasonably equivalent and compensable value for one another.

In terms of Sam Fuld and Mark Reynolds, both are part-time players who provide unique production in very different categories.  Fuld will provide stolen bases in the scarce amount of time that he plays while Reynolds produces home runs and RBI.  In contrast, Fuld offers no value in terms of home runs and RBI while Reynolds is an albatross for batting average.  Their benefits and detriments offset each other and represent sufficient and equitable compensation.  In addition, the overall packages exchange represent fair and equitable value for each other and satisfy the needs of both teams.  Based on the foregoing, the Court approves the subject trade between the Mudhen Wannabe’s and the Screaming Psychopaths.

IT IS SO ORDERED.

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