Miami Exxpos vs. Buena Vista – 6 F.J. 472 (August 2, 2014) – Fantasy Baseball Trade Review (F.Freeman/N.Cruz/Y.Cespedes)

SUPREME COURT OF FANTASY JUDGMENT

Miami Exxpos vs. Buena Vista

ON PETITION FOR WRIT OF CERTIORARI FROM
THE JABRONI LEAGUE

Decided August 2, 2014
Cite as 6 F.J. 472 (August 2014)

Factual Background

A rotisserie fantasy baseball league called the Jabroni League (hereinafter referred to as “JL” was established in 1999 and is hosted on CBS.  The JL is a 12-team mixed AL/NL keeper league where teams are permitted to maintain a maximum of six (6) players.  GM’s can either retain players under a one-year contract or a three-year contract.  If a player was acquired during the auction draft, his value escalates $5.00 the following season.  If a player was acquired via free agency, his value escalates $8.00 the following season and then $5.00 every subsequent year capped at three years of keeper eligibility.

The JL uses a standard 5×5 format for its 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.

All trades made between GM’s are subject to review.  Due to the fact that the JL is comprised of several clusters of family members and close relatives, the commissioner has the sole authority to submit all trades to the Court for review to avoid any potential conflicts.

The commissioner has submitted a trade to the Court for review to determine whether it should be approved or rejected.

Procedural History

The Miami Exxpos traded Christian Yelich (OF-MIA, cannot be kept in 2015), Freddie Freeman (1B-ATL, cannot be kept in 2015), Yoenis Cespedes (OF-BOS, can be kept for $23.00 in 2015), and Huston Street (RP-LAA, can be kept for $16.00 in 2015) to Buena Vista in exchange for  Nelson Cruz (OF-BAL, can be kept for $10.00 in 2015), Billy Butler (DH-KC, can be kept for $10.00 in 2015), Lonnie Chisenhall (3B-CLE, can be kept for $8.00 in 2015), and Andrew Heaney (SP-MIA, can be kept for $8.00 in 2015).

Issue Presented

(1)   Should the trade between the Miami Exxpos and Buena Vista 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 JL 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 Freddie Freeman, Christian Yelich, Yoenis Cespedes and Huston Street in exchange for Nelson Cruz, Billy Butler, Lonnie Chisenhall and Andrew Heaney looks slightly inequitable 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.  Steelers vs. Patriots, 3 F.J. 216, 220 (November 2011).  However, there are several star players involved on both sides of the trade.

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.  See Mudhen Wannabe’s vs. Screaming Psychopaths, 6 F.J. 399 (July 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).

It seems evident that Buena Vista made this deal with the intention of competing for the rest of this season.  We come to this conclusion based on the fact that they acquired Christian Yelich and Freddie Freeman’s expiring contracts, as well as the expensive contracts of Cespedes and Street.  On the other hand, the Miami Exxpos are continuing their fire sale in pursuit of building for the future.  They have made several trades recently demonstrating a desire to unload expensive contracts in exchange for salary cap relief and less expensive players who will be under team control going forward.  They were going to lose Freeman and Yelich at the end of the season anyway, so it makes perfect sense that they would want to obtain some form of compensation for them now rather than lose them for nothing.

In addition, the Miami Exxpos also acquired two young players who are potential keepers for only $8.00 each.  Lonnie Chisenhall has blossomed this season after several years of failing to live up to expectations.  He has become a cornerstone of the Indians future and in the middle of their potent lineup.  In addition, Andrew Heaney is one of the top pitching prospects in baseball and should have a spot in Miami’s starting rotation in 2015 despite struggling in his cup of coffee with the club earlier this season.

Even without knowing their rosters or the current standings, this deal appears to make sense from both teams’ perspectives.  See Los Pollos Hermanos vs. Little Stumps, 3 F.J. 192, 195 (October 2011) (holding that a trade will be rejected when the Court cannot objectively ascertain any benefit to one of the teams and the net result in no way makes a team better now or in the future).  Both packages contain players who hit for power and provide solid run production numbers.  The compensation being exchanged is fair and equitable, and the deal itself satisfies both parties’ respective needs.  Based on the foregoing, the Court approves the trade between the Miami Exxpos and Buena Vista.

IT IS SO ORDERED.

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