Kramer Dogs vs. 2 Louns Crew – 6 F.J. 536 (September 7, 2014) – Fantasy Baseball Trade Review (S.Castro/J.Gray/C.Granderson)

SUPREME COURT OF FANTASY JUDGMENT

Kramer Dogs vs. 2 Louns Crew

ON PETITION FOR WRIT OF CERTIORARI FROM
THE INCONTINENT LEAGUE

Decided September 7, 2014
Cite as 6 F.J. 536 (September 2014)

Factual Background

A rotisserie fantasy baseball league called The Incontinent League (hereinafter referred to as “roto league” or “IL” is a 12-team NL-only keeper league utilizing an auction-style draft and transaction platform.  Teams are permitted to maintain up to ten (10) players during each off-season with individual players allowed to be kept for a maximum of three (3) consecutive years under contract.  Each team is also permitted to keep two minor league players which are in addition to the ten players kept.  This roto league also has a $26.00 draft salary cap, as well as a $36.00 in-season salary cap that is applicable for all teams.

As with many rotisserie leagues, the Incontinent League 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 Incontinent League’s commissioner submitted a proposed trade between two league members and seeks an opinion on whether the trade should be approved.

Procedural History

The Kramer Dogs traded Jaime Garcia (SP-STL, $1.00 in the first year of his existing contract with two years remaining), Curtis Granderson (OF-NYM, $1.90 in the first year of his existing contract with two years remaining), Brandon Crawford (SS-SF, $0.50 in the second year of his existing contract with one year remaining) and Jonathan Gray (SP-COL, $0.50 on a minor league contract) to 2 Louns Crew in exchange for Starlin Castro (SS-CHC, $2.00 in the first year of his existing contract with two years remaining), Gerardo Parra (OF-ARZ, $1.30 in the first year of his existing contract with two years remaining) and Tim Hudson (SP-SF, $1.40 in the first year of his existing contract with two years remaining).

Issue Presented

(1)   Should the trade between the Kramer Dogs and 2 Louns Crew 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 IL 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 Jaime Garcia, Curtis Granderson, Brandon Crawford and Jonathan Gray in exchange for Starlin Castro, Gerardo Parra and Tim Hudson looks fair and equitable in terms of present day value.  None of the players in this deal are considered elite for purposes of requiring additional scrutiny merely because of how valuable they are.  See Steelers vs. Patriots, 3 F.J. 216, 220 (November 2011).

Typically the only circumstances where we will reject a trade are: 1) if the deal is made in violation of league rules; 2) if the deal is made through collusion; 3) the deal is so grossly lopsided that is has a detrimental effect on the whole league; and 4) if the deal makes absolutely no sense and/or fails to improve at least one of the team’s rosters in any capacity.  Grand Theft Votto vs. That Wimpy Deer, 6 F.J. 39, 42 (April 2014).  Given the circumstances surrounding this trade, we are only analyzing whether numbers 3 or 4 apply.

This trade involves the exchange of shortstops, outfielders and starting pitchers on both sides.  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).

Both GM’s in this deal have conceded the current season and are looking towards the future.  The Kramer Dogs are currently in 5th place and seven points out of 4th place and 10.5 points out of 3rd place.  With such a short amount of time left in the season, that is an insurmountable number of points to overcome.  The key acquisition for the Kramer Dogs is Starlin Castro who is one of the top shortstops in an NL-only league such as the IL.  Unfortunately Castro’s season is likely over now due to sustaining a high ankle sprain.  Despite that, the Kramer Dogs will have him under contract for the next two years at only $2.00 per season which is reasonable considering the skills and productivity that Castro provides across the board in a roto league.

There is no denying that 2 Louns Crew does sustain a projected downgrade at shortstop after trading away Castro and acquiring Brandon Crawford to fill his shoes.  But he is currently in 11th place with nothing else to lose, so this trade served other purposes to balance out that downgrade.  2 Louns Crew also acquired Curtis Granderson who has had a terrible season but is under contract for the next two years at a reasonable salary of $1.90.  He does provide an upgrade in terms of power, but he will have to significantly improve his plate discipline and gain more consistency if he is going to avoid being an albatross for batting average again in 2014.

The centerpiece of the package being obtained by 2 Louns Crew is minor league pitcher Jonathan Gray.  He should likely be in the Rockies’ rotation to start 2015 and is one of the top pitching prospects in baseball.  He was recently shut down for the remainder of the minor league season due to shoulder soreness, but the injury is not considered serious and there should not be any lingering issues heading into 2015.  The real value comes from the fact he can be retained for just $0.50 as a minor leaguer next year and then the following three years assuming he pitches for Colorado.  Of course no one can predict whether he will be successful or not, but his projected future value is significant enough today that it provides sufficient value as compensation in this trade.  The remaining players are ancillary and do not factor significantly into the equation balancing out the deal.

Both teams appear to be looking towards 2015 by making this deal.  There are players being exchanged that fulfill specific needs for both GM’s and all players involved are financially reasonable.  We have no doubts that sufficient value is being exchanged for each other.  The motivations of both teams are obvious and the deal satisfies the needs of both parties.  Based on the foregoing, the Court approves the trade between the Kramer Dogs and 2 Louns Crew

IT IS SO ORDERED.

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