The Atoms vs. Brand X – 6 F.J. 436 (July 29, 2014) – Fantasy Baseball Trade Review (Y.Puig/N.Syndergaard/E.Longoria)

SUPREME COURT OF FANTASY JUDGMENT

The Atoms vs. Brand X

ON PETITION FOR WRIT OF CERTIORARI FROM
THE NEW JERSEY BASEBALL ASSOCIATION

Decided July 29, 2014
Cite as 6 F.J. 436 (July 2014)

Factual Background

A head-to-head points-based fantasy baseball league called the New Jersey Baseball Association (hereinafter referred to as “NJBA” was established in 1999 and is hosted on CBS.  The NJBA is a 12-team mixed AL/NL keeper league where teams are permitted to maintain an unlimited number of players from one season to the next.   The NJBA conducted its draft through an online auction where each team must fill a roster with 25 players with a $260.00 budget.  The salary cap increases to $300.00 once the draft is completed.  The NJBA has the following rules regarding the selection of keepers:

Article II. Draft/Keepers

2.02  Players chosen as keepers can be kept under one of the following three conditions:

           (A) As second-year option players. These players will be designated with “opt” in their Contract field. This means that the team has   exercised a second year on the original contract and will have that player for the following season at the same value that that player had in the first year of the contract. This also means that that team may not select that player as a third year keeper. Such a player will be available in the third year auction.

           (B) Keepers may be signed to long-term contracts. The length of the contract may be any whole number of years equal to 2 or greater. The final year will be recorded in their Contract field. The value of a player’s contract increases each year of the long-term agreement by 5 dollars, beginning with the first year of the contract. At the end of the contract that player must be released to the pool of available players for the auction.

           (C)  Players who ended the prior season with the NJBA status of “Minors” and who have fewer than 130 major league AB’s and fewer than 50 major league innings pitched are eligible for the prospect pricing system. This system allows teams to keep Prospects on their rosters without having to sign a player to an option year or a long-term contract. A team is allowed to have no more than 3 players in the prospect pricing system when keepers are announced.

                   (i)   The prospect pricing system works as follows: A Prospect’s salary is determined either at the draft or is a mandatory $3 if the Prospect is picked up during the prior season.

                           1)  After the first year the salary increases $1.
2)  After the second year the salary increases $1.
3)  After the third year the salary increases $2.
4)  After the fourth year the salary increases $3.
5)  After the fifth year the minor leaguer must be released, optioned, or signed to a long-term contract.
6)  The Contract status for each of the 3 possible players will reflect ML1, ML2, etc…depending on how many years they have been in the prospect pricing system.

                  (ii)   Note you still have the option to keep the minor leaguer in your minors even after he has been promoted but he will not be eligible for the prospect pricing system once he exceeds the at-bats or innings pitched limitations affecting MLB rookie status.

The NJBA has the following rules regarding trades:

Article IV. Trading

4.01     Trades may be conducted between any teams “In Good Standing with the Treasury” at any time through the “Trading Deadline”. Further limitations on trading due to insufficient funds are outlined in Article IX.

4.02     Offseason trading is permitted and will begin on the first day of the Major League Owner’s Winter Meetings. This date will be announced via email to all members of the league. They usually begin in early December. Since it is possible that the CBS website may not be fully functioning during the offseason, any trades that cannot be executed online should be announced immediately by email to all league members by all participating teams and posted to the message board for posterity — including date, teams, and players involved.

4.03     Effective beginning with the 2006 season, all trades will be subject to a league wide vote administered through the Sportsline website and overseen by the Commissioner and Rules Committee.

               (A)       After a trade is completed, all teams will have the opportunity to either approve or object to a trade by voting on the site as prompted. The trade review process will last approximately one day. See the site’s Rules section for greater detail concerning length of review process, etc.

               (B)       Each team will have one vote.

              (C)       If during the trade review process a trade garners 5 objections (i.e., half of the non-interested owners object), the trade is sent to an independent Arbiter to provide a conclusive decision.

                             (i)         The trading teams will jointly prepare a summary of their position why the trade should be allowed. If they fail to do so in a timely manner, the trade will be blocked with no further appeal.

                             (ii)        The objecting teams will jointly prepare a summary of their position why the trade should be vetoed. If they fail to do so in a timely manner, the trade will be allowed with no further appeal.

                          (iii)       While a decision is expected within 24 hrs, if the Arbiter approves the trade, it will be made effective when it otherwise would have processed absent any league objection.

                              (iv)       The teams involved should continue to maintain their rosters and lineups, however if they so choose, they can provide the Commissioner with hypothetical lineups to set reflecting the trade’s approval by the Arbiter and retro application. These lineups must be communicated prior to each day’s lineup setting deadline. Absent any conditional lineups, a later approved trade will result in reserved players for each day on their new team.

                               (v)        The Arbiter decision is absolutely final and will be accepted by the league without further prejudice. In spirit, this means move on and turn the page.

               (D)       Trades do NOT need majority approval to be permitted. Thus, if there are fewer than 5 objections, a trade automatically goes through and no further action can be taken.

               (E)       Any team voicing their objection should not expect any anonymity. If necessary, the Commissioner may ask owners who objected to identify themselves and to provide the reasoning for the objection.

               (F)       Trades should be to the benefit of both teams involved. Owners reviewing a deal are asked to judge it objectively and fairly. No owner should approve/object to a trade based on self-interest.

(G)       Offseason trades which occur when much of the league is out of touch will be at the approval of the Commissioner, who will call for voting as he sees fit.

4.04     Any trade can also be overturned by the commissioner’s office due to the following reason:

               (A)       A player involved in a trade is found to be injured or otherwise not playing at the time of the trade. This news is discovered by a team wishing to now void the trade. As long as a team files a grievance with the commissioner’s office within 24 hours of the trade, the team may be eligible for a reversal of the transaction. In this instance, both teams will still pay the transaction fees and a $10 penalty will be assessed to both teams. To avoid this, teams negotiating trades should disclose all pertinent information regarding players to be traded. If you are the brother, son or other relative or friend of a major league player, your inside information will do you no good here.

4.05     Players traded are traded with contracts intact. There is no renegotiation of contracts.

All trades made between GM’s are subject to a league vote to determine whether it will be approved or rejected.  The commissioner has submitted a trade to the Court for review to determine whether it should be approved or rejected.

Procedural History

The Atoms traded Justin Verlander (SP-DET), Wilson Ramos (C-WAS), Mark Appel (SP-HOU), Marcell Ozuna (OF-MIA), Noah Syndergaard (SP-NYM), Justin Upton (OF-ATL), Todd Frazier (3B-CIN) and Garrett Jones (1B-MIA) to Brand X in exchange for Yasiel Puig (OF-LAD), Matt Holliday (OF-STL), Nolan Arenado (3B-COL), Ian Kinsler (2B-DET), Sonny Gray (SP-OAK), Evan Longoria (3B-TB), and Evan Gattis (C/OF-ATL).  All of the players acquired by the Atoms are in their option years and cannot be kept in 2015.  They will all be available for next season’s auction draft.

The trade received five objections from uninvolved league members which implicated Rule 4.03(C) whereby the trade has been submitted to the Court for a final determination as to whether the deal should be approved.

Issue Presented

(1)   Should the trade between the Atoms and Brand X 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 NJBA 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).

At first glance, the trade of Justin Verlander, Wilson Ramos, Mark Appel, Noah Syndergaard, Marcell Ozuna, Justin Upton, Todd Frazier and Garrett Jones in exchange for Yasiel Puig, Matt Holliday, Ian Kinsler, Nolan Arenado, Sonny Gray, Evan Longoria, and Evan Gattis looks completely inequitable based on present day value.  Despite only have just over one year’s worth of experience, Puig is already considered elite for purposes of requiring additional scrutiny merely because of how valuable he is.  Steelers vs. Patriots, 3 F.J. 216, 220 (November 2011).  None of the other players in the deal are considered elite, but there are a plethora of star players who warrant sufficient compensation when they are traded.

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).  There is a concern by the objecting league members that this trade is too lopsided.  Lopsided trades can detrimentally alter the competitive balance of the league and create a slippery slope for future trades.  The Court has no issues with the idea of trading superstar 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).

Some of the objections raised to this trade cited previous deals that either were or were not approved.  Those previous trades bear no authority on whether this deal should be approved.  The NJBA employs a league voting method to process trades, so there is no internal standard by which to evaluate the merits of a trade outside of requiring that other GM’s vote fairly without their own self-interests in mind.

The Atoms are currently in 3rd place and are clearly attempting to pursue a championship during the current season.  This is evidenced by their willingness to trade away younger, less expensive players who are under contract for the foreseeable future in exchange for a group of players whose contracts will expire at the end of the season.  In contrast, Brand X is in 7th place and has made a conscious decision to concede the current season in exchange for building a foundation for the future.  He was going to lose the players he traded away at the end of the year anyway, so it made perfect sense for him to seek compensation for those players rather than lose them for nothing.  Knights vs. Seawolves, 5 F.J. 46, 48 (May 2013) (holding that keeper leagues tend to demonstrate a dichotomy in trade strategy where one team is in a “win now” mentality coupled with a trade partner looking to build for the future by trading away expensive assets).

Under Rule 4.03(F), trades should be to the benefit of both teams involved.  There is no provision in the NJBA’s rules regarding the equity of trade based on present day or future value.  As such, we must analyze this trade based on the individual benefits afforded both teams who happen to have opposite interests.

It is indisputable that this trade instantly makes the Atoms better right now.  The additions of Puig, Holliday, Arenado, Longoria, Kinsler, Gray and Gattis all mark improvements on their roster.  However, these players are essentially rentals as their contracts will expire at the end of the season and they will be eligible for the league’s 2015 auction draft.  On the other hand, Brand X sustains significant downgrades at multiple positions for the remainder of the season.  But they have rightfully reached their own conclusion that they cannot compete in 2014 and have chosen to build for the future.  As such, there is no need to engage in a statistical comparison of the players involved in this trade because it is firmly conclusive that the package obtained by the Atoms is far superior.  See Tiger’s Blood vs. Hulkamaniacs, 3 F.J. 58, 60 (July 2011).  The question is whether the integrity of the league is affected by this trade.  We conclude that it is not.

It is plausible that Brand X could have receiver better compensation for the package he offered.  However, he had certain assets he was targeting in his strategy to rebuild for the future.  Teams are not obligated to shop players around for a more advantageous deal solely to appease skeptical league members.  See Road Runners vs. Urban Achievers, 3 F.J. 47, 50 (June 2011).  The key pieces to this deal are Noah Syndergaard, Mark Appel and Justin Verlander.  The NJBA scoring system and auction values heavily favor pitching, so obtaining minor league assets like Syndergaard and Appel are clearly desirable.  While Verlander has struggled all season, he can potentially be used as a trade chip later on.

Syndergaard is universally considered one of the top pitching prospects in all of baseball.  He will likely make his debut in 2015 as part of a young and talented Mets rotation.  Additionally, Appel is a former number one pick who was recently promoted to Double-A by Houston despite some early season struggles at Single-A.  He has enough talent and projected value to be considered a viable and valuable asset in a keeper league such as this.  Further, Brand X did also receive Justin Upton and Marcell Ozuna who are young, relatively inexpensive outfielders who can be part of a foundation going forward.

While we concede that this trade is heavily unbalanced in terms of present day value, the fact remains that both teams achieved their own respective objectives in satisfying the dichotomy of keeper league trade strategy.  The Atoms have put all their eggs in one basket to make a run at a championship this year by acquiring expensive talent who cannot be kept next season.  Brand X has made the conscious decision to rebuild and sell off talent they would otherwise lose for nothing.  In doing so, they have obtained key pieces to their rebuilding process who are considered valuable assets now and in the future.  Based on the foregoing, the Court approves the subject trade between the Atoms and Brand X.

IT IS SO ORDERED.

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