Get Shorty vs. Landry’s, et al. – 6 F.J. 650 (November 18, 2014) – Fantasy Football Trade Review (O.Beckham/A.Boldin/NE Patriots)

SUPREME COURT OF FANTASY JUDGMENT

Get Shorty vs. Landry’s, et al.

ON PETITION FOR WRIT OF CERTIORARI FROM
THE LEAGUE OF EXTRAORDINARY GENTLEMEN

Decided November 18, 2014
Cite as 6 F.J. 650 (November 2014)

Factual Background

A fantasy football league called the League of Extraordinary Gentlemen (hereinafter referred to as “LOEG”) is comprised of ten (10) teams who compete against each other on a weekly basis during the National Football League (“NFL”) season using the statistics of professional players as a basis for accumulating points in head-to-head competition with opponents to determine which fantasy team won or lost.  The LOEG is hosted on the CBSSports fantasy football platform and is governed by a league constitution that was distributed to all team owners before the draft.

The governing document is a combination of settings selected using the CBSSports commissioner services as well as written rules and guidelines authored by the league commissioner in the form of a constitution.   The relevant rules pertaining to this case are as follows:

5.   TRADES

5.1 All trades are subject to commissioner approval. Trades involving the commissioner require approval of the deputy commissioner and trades between the commissioner and the deputy commissioner must be approved by Ike.

5.2 Trades will be approved unless collusion is suspected or the commissioner deems that the trade could upset the competitive balance of the league (taking into consideration a comparison of the statistics between the players involved in the trade, the roster needs of both teams, consideration of where both teams are in the standings, etc.) Collusion is defined as “an agreement between two or more teams with fraudulent intent to benefit from undermining the rules”. The commissioner has the authority to reverse trades where he believes collusion has occurred. If a member of the league feels that collusion has occurred involving the commissioner they may make an appeal to The Fantasy Judge.

5.5  Trades must be completed with all players changing teams at the same time (e.g., it is not acceptable to keep a player until after he plays an additional week for his current team).

5.6  Teams may acquire or trade waiver priority position in exchange for players. These trades shall be evaluated using the same criteria as in Rule 5.2.

5.7  Trades of draft picks and/or draft position are permitted only during the off season. Trading during the draft is permitted. Any trading of draft picks must be submitted to the commissioner for approval.

8.     FANTASY JUDGE

8.1  Any league member that wishes to dispute a commissioner ruling may do so by requesting that their case be brought in front of The Fantasy Judge. Both sides will present their arguments and the Fantasy Judge will issue a final ruling. Each team will be allowed an unlimited number of challenges until they lose three that were initiated by them in one season, at which point they will no longer be allowed to dispute a commissioner’s ruling. All challenges to the judge must go through the commissioner.

On November 18, 2014, a trade was made between The Landry’s and The Great One.  The Landry’s traded Odell Beckham, Jr. (WR-NYG) and Anquan Boldin (WR-SF) to The Great One in exchange for the New England Patriots defense/special teams.

Procedural History

The commissioner approved this trade which was subsequently challenged by Get Shorty arguing the trade was not equitable.

Issue Presented

(1) Should the trade between The Landry’s and The Great One 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 Odell Beckham, Jr. and Anquan Boldin in exchange for the New England Patriots defense/special teams looks inequitable 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).

This trade includes a swap of a two wide receivers in exchange for a team defense.  When a trade such as this is consummated involving the exchange of players at 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).

When analyzing the fairness and equity of a trade, the Court will consider each team’s individual needs to assess whether the trade subjectively made sense from each team’s perspective.  See Cajun Crawdads vs. Carson City Cocks, 1 F.J. 41, 42 (June 2010) (upholding a trade for Jason Bay because of the Carson City Cocks’ desperate need for a starting outfielder due to the demotion of Cameron Maybin).  In this case, we can see from these teams’ rosters that The Landry’s wanted to improve their team defense as they only had the 49ers and argue that their schedule is rough coming up as the fantasy playoffs approach.  In addition, The Great One was looking to bolster its quality and depth at wide receiver.

The Landry’s have Brandon Marshall, Jeremy Maclin and Sammy Watkins at wide receiver, so they had the flexibility and depth to trade away Beckham and Boldin.  Fantasy GM’s are motivated to trade from positions of strength and surplus while also capitalizing on a player’s value when it reaches its peak.  See Two Eggs Odorizzi vs. In Pursuit of the Grail, 6 F.J. 84, 86 (April 2014).  There is no question that Beckham’s value has peaked right now after becoming the Giants’ number one receiver.  He was able to use this depth and surplus to improve at another position he so desires.

We understand that the combination of Beckham and Boldin may produce more points and collectively appears to be a better package than the Patriots defense/special teams.  We also understand why Get Shorty would oppose the deal because of how it improves The Great One’s team.  However, fantasy GM’s are not obligated to shop players around for a more advantageous deal solely to appease skeptical league members.  See Road Runners vs. Urban Achievers, 3 F.J. 47, 50 (June 2011).

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 not so disparate as to be considered lopsided to the detriment of the overall league.  Based on the foregoing, the Court approves the subject trade between The Landry’s and The Great One.

IT IS SO ORDERED.

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