In Pursuit of the Grail vs. Screaming Psychopaths – 6 F.J. 5 (February 26, 2014) – Fantasy Baseball Trade Review (H.Ramirez/D.Brown)

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 February 26, 2014
Cite as 6 F.J. 5 (February 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 pre-draft trade between two league members and seeks an opinion on whether the trade should be approved.

Procedural History

In Pursuit of the Grail traded Dominic Brown (OF-PHI, $9.00 salary in 2014) to the Screaming Psychopaths in exchange Hanley Ramirez (SS-LAD, $19.00 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.

At first glance, the trade of Domonic Brown in exchange for Hanley Ramirez looks fair and equitable.  Neither of the players involved in this deal are considered elite for purposes of requiring additional scrutiny merely because of how valuable they are based on their statistics and name recognition  See Steelers vs. Patriots, 3 F.J. 216, 220 (November 2011).

This deal satisfies the needs of both teams.  While Hanley Ramirez is certainly one of the top fantasy players at a scarce position, the Screaming Psychopaths also have Troy Tulowitzki on their roster.  Of course one strategy could be to keep them both, but instead the Screaming Psychopaths are electing to use the depth they have accumulated and fill another need.  Dominic Brown instantly becomes their best outfielder besides Jayson Werth and offers much needed power on their roster.

On the other hand, In Pursuit of the Grail has much better depth in their outfield including Jose Bautista, Jason Heyward and Josh Hamilton.  In return for Brown, they are receiving a major upgrade at shortstop in Ramirez who is exponentially better than incumbent Starlin Castro.  Granted, Castro is coming off of a terrible season so his value is at an all-time low.  If he does manage to rebound, then In Pursuit of the Grail will have the luxury of having two good shortstops.

While there is a $10.00 difference in their salaries, it is not significant enough to create any inequity between the teams.  Ramirez is more established and warrants the higher price tag.  Brown is only coming off of his first full season, so his salary will continue to escalate assuming he continues to produce and is retained from year to year.

This deal makes 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).  Based on the foregoing, the Court approves the trade between In Pursuit of the Grail and the Screaming Psychopaths.

IT IS SO ORDERED.

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