Centaurs vs. Darkhorse – 6 F.J. 625 (November 17, 2014) – Fantasy Football Trade Review (T.Hilton/P.Garcon)

SUPREME COURT OF FANTASY JUDGMENT

Centaurs vs. Darkhorse

ON PETITION FOR WRIT OF CERTIORARI FROM
THE COUCH POTATO FOOTBALL LEAGUE

Decided November 17, 2014
Cite as 6 F.J. 625 (November 2014)

Factual Background

A fantasy football league called the Couch Potato Football League (hereinafter referred to as “CPFL”) is a 16-team standard keeper league created in 1989 and hosted on MyFantasyLeague.com.  Every year, each team may select six (6) players to keep which includes three offensive players and three defensive players.

The CPFL employs the following scoring system: Offense (1 point per 20 yards passing, 1 point per 10 yards rushing and receiving, 3 points per passing touchdown, 4 points per rushing or receiving touchdown, and -1 point per interception thrown); Defense (0.5 points per tackle, assist or batted ball, 1.5 points per ½ sack, 3 points per sack or interception, and 3 points per defensive touchdown); and Kicking (-1 point per missed field goal, 3 points per field goal made under 49 yards, and 4 points per field goal made 50 yards or more).

The CPFL has the following rules regarding trades:

8.     TRADING

         A. If you trade a draft pick, you must receive the same number of draft picks back.

         B. All trades will be sent to Fantasy Judgment for review.

         C. Trades will take place from the start of the season (owners meeting) until after the 8th week of the season.

         D. No trades will be allowed after the keepers are announced until after the draft.

               *          *          *          *          *

         F. Players traded after midnight on Friday during the season will not go through until the following Tuesday.

The CPFL commissioner has submitted a trade to the Court for review.

Procedural History

The Centaurs traded T.Y. Hilton (WR-IND) and its 17th and 18th round draft picks in 2015 to Darkhorse in exchange for Pierre Garcon (WR-WAS) and its 2nd and 3rd round draft picks.

Issue Presented

(1) Should the trade between the Centaurs and Darkhorse 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.

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 concerns over this trade, we will only look at scenarios 3 and 4.

In a vacuum, the trade of T.Y. Hilton and a 17th and 18th round draft pick in exchange for Pierre Garcon and a 2nd and 3rd round draft pick looks fair and equitable in terms of both present day and future value.  Hilton is not yet considered elite but he is certainly one of the best up and coming wide receivers in the league.  As such, we do not need to implement additional scrutiny simply because Hilton is involved in this trade.  See Steelers vs. Patriots, 3 F.J. 216, 220 (November 2011).

This trade includes a swap of wide receivers along with draft picks.  Draft picks in subsequent seasons are assets commonly bartered in keeper leagues.  See Bald Eagles vs. Weasel D, 3 F.J. 205, 208 (November 2011).  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).

Hilton and Garcon are heading in different directions in their career at this point.  Hilton has emerged as one of the best young wide receivers in the league amassing 59 receptions for 961 yards and three touchdowns.  He has the fortune of having one of the best quarterbacks in the league throwing the ball to him in a high-powered aerial attack.  In a keeper league such as this, he provides great value going forward.

On the other hand, Garcon has been a forgotten man in Washington with only 43 receptions for 464 yards and three touchdowns.  This is especially disappointing after a 2013 season where he had 113 catches for 1,346 yards.

With these two players providing disparate long-term value, the two GM’s have made up for the difference by exchanging these draft picks.  The Centaurs appear to be trying to rebuild through the draft by acquiring a 2nd and 3rd round draft pick in this deal.  On the other hand, Darkhorse is likely pursuing the playoffs this year by acquiring Hilton who is currently thriving in Indianapolis.

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).  Here, the trade makes sense from both teams’ perspectives and serves their respective needs.  The compensation being exchanged is fair and equitable in terms of both present and future value.  We see no reason why this trade should not go through.  Based on the foregoing, the Court approves the subject trade between the Centaurs and Darkhorse.

IT IS SO ORDERED.

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