Jersey Shore GTL vs. Professional Amateurs – 3 F.J. 1 (March 17, 2011) – fantasy baseball trade rejected

SUPREME COURT OF FANTASY JUDGMENT 

Jersey Shore GTL vs. Professional Amateurs

 ON PETITION FOR WRIT OF CERTIORARI FROM THE CALIFORNIA PENAL FANTASY BASEBALL LEAGUE

 Decided March 17, 2011

Cite as 3 F.J. 1 (March 2011)

Factual Background

A rotisserie fantasy baseball league named the California Penal Fantasy Baseball League (hereinafter referred to as “CPFBL”) utilized an auction-style draft hosted on Yahoo’s fantasy baseball commissioner platform.  The CPFBL is a 12-team rotisserie league using both AL and NL players with each team allowed to keep up to five players for a maximum of three seasons.  Like many rotisserie leagues, the CPFBL is a 5×5 league using the standard hitting and pitching categories (AVG, HR, RBI, Runs, SB, W, ERA, K’s, SV, WHIP).  Statistics are cumulative throughout the season and each team will accrue points based on their standings for each individual scoring category.  Each team has a budget of $260 to draft 25 players and then $100 to purchase free agents after the draft has concluded.

The CPFBL draft is scheduled to take place on Sunday, March 27, 2011 at 12:00 PM CST.  The rules and guidelines of the league are delineated in a written document called the “CPFBL Constitution.”  Contained within the CPFBL Constitution is a section entitled “Trading and Transactions” which is marked as Article III.  Under Article III is a provision III.A entitled “Trades Between Teams” which includes the following pertinent sub-provisions:

1.   Teams shall be permitted to trade players during the off-season, which is defined as the time period starting the day after the conclusion of the World Series through the day before the next season’s draft.

4.   Teams shall not be permitted to trade draft picks or any other intangible asset.

5.   Trades made between teams must be of fair value and free from collusion.

8.   The CPFBL Commissioner shall have sole authority to approve or reject all trades proposed and entered into.

Procedural History

Two teams in the CPFBL – the Professional Amateurs and Jersey Shore GTL – attempted to make a trade prior to the league’s draft that has been rejected by the league’s Commissioner.  The Professional Amateurs offered Tim Lincecum-SP-SF, in the final year of his contract, to Jersey Shore GTL in exchange for Brett Anderson-SP-OAK plus $30 in salary cap flexibility. 

The Commissioner rejected this trade on the basis that the league’s Constitution prohibiting trades involving intangible assets.  The Commissioner reasoned that the $30 in salary cap money is intangible and cannot be traded according to the league’s rules.

The Professional Amateurs and Jersey Shore GTL have challenged the Commissioner’s ruling by arguing that the $30 is tangible since it will be used to draft players at the auction, and that it represents fair monetary value for Lincecum.

Issue Presented

(1)   Should the trade between the Professional Amateurs and Jersey Shore GTL be upheld and approved?

Decision

The Supreme Court of Fantasy Judgment typically favors individual fantasy sports participants and teams’ ability to make moves, transactions, and trades.  The standard of review has been that people pay money to purchase a team in a league, draft their team, and manage it accordingly.  Whether success is bred from that individual’s decision-making is purely left to some skill, luck, dedication, and savviness.  The Court also acknowledges that the analysis for evaluating trades is much different in a keeper league than a non-keeper league.  A trade that may look uneven or lopsided on its face may receive a different opinion when it is involved in a keeper league.  The reasons for this are obvious, but must be restated.  In a keeper league, teams that are having unsuccessful seasons are more likely to continue to pay attention and make moves that will set themselves up for better success in the following season.  They can do this by acquiring young talent that is not under contract within the league, or by dumping salary (assuming it is an auction league) and allowing greater financial flexibility to sign key players in the next season’s draft.  In non-keeper leagues, there is no rationale for thinking ahead, nor is there any need to stockpile young, inexpensive talent.

Another factor that the Court must always consider is whether there is any collusion or under-the-table dealings going on between teams.  The Court has not been presented with any evidence of such malfeasance, so assumptions will be made that this is not an issue. 

Normally the Court will look at the players involved in the trade and arbitrarily render an opinion on the fairness and equitability of the subject players’ talents, abilities and statistics.  However, this is an issue of first impression as the Court has never been faced with an attempted trade of players in exchange primarily for salary cap money.  Without question, the trade of Tim Lincecum for Brett Anderson straight up is not an even trade, despite Lincecum being in the final year of his fantasy contract.  Anderson is a highly touted young pitcher with great potential, but he is far from the level of the two-time Cy Young award winner. 

Before analyzing the legality of the trade, the Court will take this opportunity to state that Brett Anderson plus $30 in salary cap money does represent fair value for Lincecum.  In many auction drafts researched by the Court, Lincecum’s value has ranged on average between $25 – $38.  On its face, the trade as proposed is fair.

However, the Commissioner properly rejected this trade based on his interpretation of the CPFBL’s Constitution.  The Supreme Court of Fantasy Judgment is a strong advocate for having written Constitutions that govern fantasy sports leagues because “all league members are aware of the rules and guidelines in place, and it shifts the burden onto the league members to read, understand, and adhere to the rules that are delineated.”  See Shawn Kemp is My Daddy v. Fantasy Basketball League Commissioner, 2 F.J. 24, 25 (October 2010).  Here, there was clear language in the Constitution that prohibits trading intangible assets.  While the rules do not specifically list salary cap money under the definition of “intangible asset,” the Court can clearly interpret that salary cap money is inclusive in this provision.  The rules also state that the Commissioner has sole authority to approve or reject trades.  Here, the Commissioner was well within his authority to make this decision, which happens to be the correct one pursuant to the rules that govern the league.  Despite arguments made by the teams involved, the Commissioner rejected the notion that salary cap money was not considered an intangible asset.  The Court bolsters this position by holding that the league does not permit trading draft picks, which is arguably the same thing as salary cap money.  They both are intangible assets that can be used to acquire players.  Because there is no distinction between the two, the Court agrees with the Commissioner’s decision.

Further, this trade should not be permitted because it would violate the salary cap limitations set by the Commissioner and Yahoo.  If the trade was allowed, then the Professional Amateurs would have $290 in salary cap money to bid on players.  This directly contradicts the settings of the league where each team is permitted $260. 

Based on the aforementioned reasons, the Commissioner properly rejected this trade between the Professional Amateurs and Jersey Shore GTL.  The Court hereby upholds the Commissioner’s decision and rules that the subject trade should be rejected as it is in direct violation and contradiction of the league’s explicit rules.

IT IS SO ORDERED.

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