It’s Good to be JV vs. Screaming Psychopaths vs. In Pursuit of the Grail – 6 F.J. 51 (April 13, 2014) – Three-Way Fantasy Baseball Trade (M.Cabrera/C.Kershaw/C.Gonzalez)

SUPREME COURT OF FANTASY JUDGMENT

It’s Good to be JV vs. Screaming Psychopaths vs. In Pursuit of the Grail

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

Decided April 13, 2014
Cite as 6 F.J. 51 (April 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 three-way trade amongst three league members and seeks an opinion on whether the trade should be approved.

Procedural History

It’s Good to be JV traded Clayton Kershaw (SP-LAD, $36.00 salary in 2014), Cliff Lee (SP-PHI, $27.00 salary in 2014), Chris Johnson (3B-ATL, $1.00 salary in 2014), and Casey Janssen (RP-TOR, $9.00 salary in 2014) and acquired Miguel Cabrera (3B-DET, $43.00 salary in 2014), Omar Infante (2B-KC, $2.00 salary in 2014), Jesse Crain (RP-HOU, $1.00 salary in 2014), and Rafael Soriano (RP-WAS, $7.00 salary in 2014).  The Screaming Psychopaths traded Miguel Cabrera, Omar Infante, and Rafael Soriano and acquired Carlos Gonzalez (OF-COL, $40.00 salary in 2014), Chris Johnson, Adam LaRoche (1B-WAS, $5.00 salary in 2014), and Casey Janssen.  In Pursuit of the Grail traded Carlos Gonzalez and Adam LaRoche and acquired Clayton Kershaw and Cliff Lee.

Issue Presented

(1)   Should the three-way trade between It’s Good to be JV, Screaming Psychopaths, and In Pursuit of the Grail 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, this three-team trade involving the exchange of several elite players does look fair and equitable.  Within this deal, Miguel Cabrera, Clayton Kershaw, and Carlos Gonzalez are all considered elite for purposes of requiring additional scrutiny to ensure that fair and equitable value is being exchanged for them.  See Steelers vs. Patriots, 3 F.J. 216, 220 (November 2011).  It just so happens that these three players are all being acquired by three separate teams, so that in itself tends to indicate that fair value is being exchanged on all ends of the deal.

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 acquisition of Miguel Cabrera makes sense on any level given what a prolific hitter he is, but it makes even more sense due to the fact that It’s Good to be JV previously traded away his third Pablo Sandoval in a prior deal.  See It’s Good to be JV vs. The Greatest Man That Ever Lived, 6 F.J. 47 (April 2014).  However, what is more fascinating is the extreme shift in pitching philosophy that they are employing by making this deal.  JV is trading away both Clayton Kershaw and Cliff Lee.  Despite Kershaw’s current injury, he is in position to dominate many of the pitching categories with a staff that is also comprised of Justin Verlander and Felix Hernandez.  But it is this depth which has allowed him to deal from such a position of strength and obtain arguably the best hitter in baseball in Cabrera.

In addition, JV has obtained Rafael Soriano which gives him another closer along with Trevor Rosenthal and Ernesto Frieri.  This allows him to ascend the standings in the saves category while still possessing enough starting pitching to compete for wins and strikeouts.

In Pursuit of the Grail is clearly focusing on improving their pitching by acquiring both Kershaw and Lee.  This is very risky given the fact that Kershaw is still on the disabled list and his return is not known at this time.[1]  While he clearly possesses tremendous value as a keeper, we must look at what In Pursuit of the Grail is obtaining in him for the current season.  Right now the common belief is that Kershaw will be back in May and is expected to perform at the elite level we are accustomed to.  However, if this trade was consummated a few weeks from now and there was no time frame for his return, the Court may downgrade his potential value for the current season.

Furthermore, In Pursuit of the Grail is also trading away an elite outfielder in Carlos Gonzalez after recently acquiring him.  See In Pursuit of the Grail vs. Screaming Psychopaths, 6 F.J. 35 (April 2014).  This is a bit risky considering his two best remaining outfielders are Jacoby Ellsbury and Matt Kemp who are both injury-prone.

The Screaming Psychopaths sustained a major downgrade at third base by trading away Cabrera and acquiring Chris Johnson.  However, they obtained Carlos Gonzalez which gives them an elite outfield along with Ryan Braun and Adam Jones.  They can make up for the batting average, power and run production of Cabrera, and they also provide much more in terms of runs scored and stolen bases.

The remaining players in the deal are all ancillary and do not affect the overall value or composition of the deal.  As complex, unique and star-studded as this trade is, it makes perfect sense from all three 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).  There is risk involved for all three teams, just as there are tangible benefits being obtained.  Based on the foregoing, the Court approves this three-team trade amongst It’s Good to be JV, the Screaming Psychopaths, and In Pursuit of the Grail.

IT IS SO ORDERED.

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