In Pursuit of the Grail vs. Screaming Psychopaths – 6 F.J. 411 (July 21, 2014) – Fantasy Baseball Trade Rejected (M.Melancon/A.LaRoche/J,Reddick)

SUPREME COURT OF FANTASY JUDGMENT

In Pursuit of the Grail 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. 411 (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 C.J. Cron (1B-LAA, $5.00 salary in 2014) and Josh Reddick (OF-OAK, $9.00 salary in 2014) to the Screaming Psychopaths in exchange for Nick Swisher (1B/OF-CLE, $9.00 salary in 2014), Mark Melancon (RP-PIT, $5.00 salary in 2014) and Adam LaRoche (1B-WAS, $5.00 salary in 2014).

Issue Presented

(1)   Should the trade between In Pursuit of the Grail 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 C.J. Cron and Josh Reddick in exchange for Nick Swisher, Mark Melancon and Adam LaRoche 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 all 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 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, In Pursuit of the Grail is in 4th place in his division and arguably could still be competing for the current season.

Josh Reddick is due to come off the disabled list this week after missing several weeks due to a knee injury.  Before he got hurt, Reddick was barely rosterable with only a .224 batting average and just four home runs and 24 RBI.  While he has never hit for batting average, it looks as though his 2012 season with 32 home runs was an outlier.  Oakland has played extremely well without Reddick, so it could be difficult for him to see regular at bats if he continues to struggle after coming back.

C.J. Cron was just demoted to the minor leagues after the Angels acquired Huston Street.  Cron was batting .268 with nine home runs and 27 RBI in only 175 at bats, so he certainly was a serviceable option at corner infield or utility.  But now that he is in the minor leagues, his value for the remainder of the season is in serious jeopardy.

With the combination of Reddick and Cron having very limited present day value, we must determine whether the package being sent to In Pursuit of the Grail is fair and equitable without affecting the competitiveness of the league in terms of the rest of 2014.  While Swisher, LaRoche and Melancon are not superstar players by any means, their collective value and production is far superior to that of Cron and Reddick for the rest of 2014.  It is for that reason why the Court believes this trade to be inequitable under the CAFBL’s rules.

Swisher is an albatross in the batting average category, but he does have nine home runs and 40 RBI despite struggling massively and being out with an injury earlier this year.  With Michael Bourn now injured, Swisher will continue to see regular playing time and he has already gotten himself out of a prolonged slump.  Plus, he has eligibility at multiple positions which increases his value.  In addition, Adam LaRoche has put up respectable numbers thus far despite having a big slump earlier in July.  To date, he is batting .277 with 12 home runs and 48 RBI.  The combination of both Swisher and LaRoche drastically outperforms what Reddick and Cron have already produced and what they are likely to produce for the rest of the season.

Even after already concluding that the exchange of offensive players is disparate, adding Mark Melancon to the equation tips the balance even more.  Melancon has been dominant as the Pirates new closer amassing 18 saves with a terrific 2.21 ERA and 0.87 WHIP.  He is not a top tier closer by any means, but he has a lot of value closing for a good Pirates team that plays a lot of close games.

Under the CAFBL’s rules, we must determine whether the present day value of the players involved in a trade has a detrimental effect on the competitiveness and integrity of the league during the current season.  Here, the combination of Reddick and Cron provides minimal present day value.  The package of Swisher, LaRoche and Melancon is far superior and the disparity cannot be ignored.  Based on the foregoing, the Court rejects the subject trade between In Pursuit of the Grail and the Screaming Psychopaths.

IT IS SO ORDERED.

Facebooktwittergoogle_plusredditpinterestlinkedinmailby feather