Cadaret Plunk, LLC vs. 3-Year Plan – 6 F.J. 516 (August 19, 2014) – Fantasy Baseball Trade Rejected (A.McCutchen/A.Chapman/H.Rondon)

SUPREME COURT OF FANTASY JUDGMENT

Cadaret Plunk, LLP vs. 3-Year Plan

ON PETITION FOR WRIT OF CERTIORARI FROM
THE SCOTT BARRETT MEMORIAL LEAGUE

Decided August 19, 2014
Cite as 6 F.J. 516 (August 2014)

Factual Background

A rotisserie fantasy baseball league called The Scott Barrett Memorial League (hereinafter referred to as “SBML” is a 12-team NL-only keeper league utilizing an auction-style draft and transaction platform.  The SBML has been in existence since 1999 and is hosted on the CBS platform.  Rosters consist of 24 players which include 10 pitchers and 14 hitters.  Each team is allotted a $260.00 salary cap on draft day and a $360.00 maximum salary cap for active rosters during the season.  Keepers can have contracts of up to three (3) years.  Players can be kept at the same salary in year one, and then salaries increase by $5.00 per year in years two and three.

As with many rotisserie leagues, the SBML 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.  Statistics are cumulative throughout the course of the season and there are no head to head games contained within the Roto league.

The SBML’s commissioner is responsible for all trade approvals.  The league will typically utilize a committee to resolve trade disputes.  However, there have been several instances where GM’s have argued over the value of keepers versus expiring contracts.  As such, the SBML commissioner has submitted a proposed trade between two league members and seeks an opinion on whether the trade should be approved.

Procedural History

Cadaret Plunk, LLP traded Hector Rondon (RP-CHC, $16.00 salary and can also be signed to a three-year contract after the season) plus the expiring contracts of Andrew McCutchen (OF-PIT, $36.00), Michael Cuddyer (OF-COL, $15.00) and Lance Lynn (SP-STL, $6.00).to 3-Year Plan in exchange for Aroldis Chapman (SP-CIN, $15.00 and can also be signed to a three-year contract after the season).  This trade does not put 3-Year Plan over the $360.00 in-season salary cap, nor does it violate any team rules.  There is opposition to this trade based on the belief that the deal is heavily weighted in favor of 3-Year Plan.

Issue Presented

(1)   Should the trade between Cadaret Plunk, LLP and 3-Year Plan 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 SBML 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 Hector Rondon, Andrew McCutchen, Michael Cuddyer and Lance Lynn in exchange for Aroldis Chapman looks completely inequitable in terms of present day value.  McCutchen is considered elite for purposes of requiring additional scrutiny merely because of how valuable he is.  See Steelers vs. Patriots, 3 F.J. 216, 220 (November 2011).   The 2013 National League MVP has been out the past couple weeks with a fractured rib, but he has just been activated and returned to the Pirates’ lineup.  McCutchen is unquestionably one of the top players in fantasy baseball, especially an NL-only league such as this.

Given the way this trade is constructed, there is no need for us to engage in a statistical analysis of the players involved.  The packages are so clearly disparate that it would be a waste of judicial economy to do so.  See Tiger’s Blood vs. Hulkamaniacs, 3 F.J. 58, 60 (July 2011).  This appears to be a classic dump trade where one team that is out of contention attempts to disperse of its most valuable assets in pursuit of rebuilding for the future.  Cadaret Plunk, LLP is currently in 5th place and is 7.5 points behind their trading partner, 3-Year Plan, who is currently in 4th place.  Despite being such close proximity in the standings, it is obvious that these two teams are heading in polar opposite directions which epitomize the dichotomy of keeper league trade strategy.  Knights vs. Seawolves, 5 F.J. 46, 48 (May 2013) (defining the dichotomy as when one team in contention has a “win now” mentality by acquiring more expensive players coupled with a trade partner that is building for the future by selling off assets).

When a GM in a keeper league no longer has any hope for contending in the current season, he/she must make a critical roster management decision of whether to trade off valuable and expensive assets in order to build for the future.  See Winners vs. Seven Shades of Shite, 3 F.J. 97, 102 (July 2011).  Now that Cadaret Plunk, LLP has made that decision, it makes perfect sense why they would want to trade the expiring contracts of McCutchen, Cuddyer and Lynn.  He will lose these players at the end of the season anyway, so it is understandable that he is seeking to obtain some form of compensation for them rather than lose them for nothing.  The issue is whether the compensation received for this package of rental players is sufficiently equitable/

While we must look at trades in keeper leagues much deeper than simply by comparing the names and values of the players exchanged, there are limitations to what GM’s are entitled to do without jeopardizing the integrity of the league.  Lopsided trades throw off 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).

The real question at the heart of this dispute is reconciling the value of potential keepers with the value of players who have expiring contracts.  Because this the crucial question to consider, we can easily conclude that the trade itself is not equitable.  We must determine whether its inequity can be overcome by the other factors that are evaluated when analyzing trades in keeper leagues.  Grave Diggers vs. Chilidogs, 4 F.J. 5, 8 (January 2012); see also Harem Hawkings vs. Harbor Yankees, 4 F.J. 40, 42 (April 2012) (holding that a more expensive player could be financially prohibitive in the long run compared to a cheaper player who offers more financial flexibility).

Cadaret Plunk, LLC is only receiving Aroldis Chapman in the deal.  Granted, he is one of the better closers in baseball and is eligible to be retained on a long-term contract.  But in this NL-only league, he is still at the very most the third best closer in the league behind Craig Kimbrel and Kenley Jansen despite having incredible peripheral numbers including averaging almost two strikeouts per inning.  So clearly Cadaret Plunk, LLC has made it a priority to either upgrade or stabilize his position with respect to saves.  GM’s are free to prioritize the areas on their rosters that they want to pursue improvement 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).

In exchange for Chapman, 3-Year Plan is receiving a dynamic group of players which include McCutchen, Cuddyer, Lynn and Rondon.  Like Chapman, Rondon is eligible to be retained via a long-term contract.  He has emerged as the Cubs closer this year and has accumulated 18 saves pitching for a bad team.  While Chapman is better (26 saves despite missing over a month to start the season after being hit by a batted ball in his face), it is arguable that Rondon alone presents equitable compensation for Chapman.

Assuming arguendo that Chapman for Rondon is an equitable exchange, we must look at what happens to the trade when you add McCutchen, Cuddyer and Lynn to the deal.  Despite the fact that these three players are merely rentals for the rest of the season, the fact remains that they are huge difference-makers because they are essentially being acquired for nothing.  It doesn’t even matter whether Chapman is kept under a long-term contract or not.  The fact is that a very valuable package is being sent to 3-Year Plan in exchange for grossly inequitable value.

Expiring contracts are assets to use in trade negotiations in order to procure presumably less expensive and contractually controlled talent back in exchange.  It is understandable and reasonable to expect GM’s not to get full value for high-caliber players who have expiring contracts.  But it is cause for concern when they are traded away for ten cents on the dollar.  The 3-Year Plan is receiving a complete windfall from this deal which could have significant effects on the overall standings for the rest of the season.

Normally the Court is very liberal with its views on keeper league trades as we support and endorse fantasy GM’s abilities to manage their teams according to their own preferences.  But we have never hesitated to intervene when a trade is simply too disparate to look past.  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.  See Los Pollos Hermanos vs. Little Stumps, 3 F.J. 192, 195 (October 2011); see also Speedboys vs. Kramerdogs, 5 F.J. 109 (July 2013) (rejecting a trade of Paul Goldschmidt, Adam Wainwright and Rafael Soriano in exchange for Bryce Harper, A.J. Burnett Trevor Rosenthal, and Archie Bradley).  Because the exchange of Chapman for Rondon is close enough to consider equitable, we cannot ascertain any other benefit that is being afforded to Cadaret Plunk, LLC by including the expiring contracts of McCutchen, Cuddyer and Lynn in this deal.

White it is normally acceptable for teams in keeper leagues to make trades that do not have equivalent present-day value, a deal that is so completely lopsided and goes against the best interests of the league will be rejected.  See Smittydogs vs. Moneyball, 4 F.J. 57 (May 2012) (rejecting a trade of Ryan Braun and Edwin Jackson in exchange for Randall Delgado, Dee Gordon and Bobby Abreu); Team Sabo vs. 4 Ponies, 4 F.J. 50 (May 2012) (rejecting a trade of Joey Votto and Tyler Clippard in exchange for Drew Stubbs, Francisco Rodriguez and Starling Marte).  While fantasy GM’s may have many objectives for making trades to rebuild for the future, those benefits can be trumped by the inequitability of the current players being traded away.  Beaver Hunters vs. 4 Ponies, 4 F.J. 129, 131 (July 2012).  That is exactly what we have here.  Based on the foregoing, the Court rejects the trade between Cadaret Plunk, LLC and 3-Year Plan.

IT IS SO ORDERED.

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