Smittydogs vs. 2 Louns Crew – 3 F.J. 119 (August 7, 2011) – fantasy baseball trade (M.Bourn/D.Freese)


Smittydogs vs. 2 Louns Crew 


Decided August 7, 2011

Cite as 3 F.J. 119 (August 2011) 

Factual Background

A rotisserie fantasy baseball league (hereinafter referred to as “Roto league” or “The Incontinent League”) utilizing an auction-style draft and transaction platform seeks an evaluation of a trade made between two teams within the Roto league.  This is an NL-only keeper league where each team is permitted to maintain up to ten (10) players during each off-season with each individual player allowed to be kept for a maximum of three (3) years.  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 $36.00 in-season salary cap that is applicable for all teams.   

As with many rotisserie leagues, the subject Roto 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.

Procedural History

The Smittydogs have made a trade with 2 Louns Crew.  The Smittydogs traded David Freese (3B-STL) to 2 Louns Crew in exchange for Michael Bourn (OF-ATL).

Issue Presented

(1)   Should the trade between the Smittydogs and 2 Louns Crew be upheld and approved?


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.  See Smittydogs v. Moneyball, 1 F.J. 32, 33 (June 2010).

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. 

At first glance, the trade of David Freese in exchange for Michael Bourn looks fair and even.  Neither player is regarded as a superstar, but Bourn does have intrinsic roto value due to his stolen base numbers.  Freese has spent a lot of time on the disabled list, but he has shown an ability to produce respectable offensive numbers when healthy and hitting in a potent Cardinals’ lineup that includes Albert Pujols and Matt Holliday.  Bourn was just acquired by the Atlanta Braves to be their leadoff hitter, so he will have plenty of chances to produce in a pennant race down the stretch.  Freese is also on a team in a pennant race, so he will play everyday.  He was removed from the game on August 7, 2011 after being hit in the head, but the medical reports out of St. Louis indicate he will be cleared to play come August 9, 2011. 

The following is a statistical comparison of the players involved in the trade:







Michael Bourn






David Freese






Based on this statistical comparison, the numbers are equivalent enough to conclude that the value is comparable outside of the tremendous disparity in stolen bases. 

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 Cajon 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).  This trade involves an outfielder in exchange for a player who qualifies at both first base and third base.  The Smittydogs have been lacking in stolen bases, especially since Carlos Gonzalez has been injured.  His need for outfield speed is obvious as Bourn now represents his only stolen base threat until Gonzalez returns.  On the other hand, 2 Louns Crew, currently in last place, does not have anyone else who can replace Bourn’s production in terms of stolen bases.  However, Freese qualifies at first base and he represents a marked improvement over the options he currently has in James Loney and Miguel Cairo.  In a roto league where stolen bases have such a significant impact, a player such as Bourn is very highly regarded due to his unique value of stealing bases.  But Freese does have better power numbers, which have been somewhat deflated this year due to missing time with an injury.  When healthy, Freese is capable of producing similar if not better numbers than Bourn in all categories except stolen bases.  Based on the foregoing analysis, the needs of each team were equally met with this trade.

In terms of keeper league status and salary cap value, this trade provides benefits to both parties.  Bourn is in his first year under contract at $2.70, and at his age, he can still contribute speed statistics for the next two years as well.  In contrast, Freese is in his second year under contract at only $0.50.  This will give 2 Louns Crew an extra $2.20 in salary cap flexibility, which is significant in the Incontinent League.  .

As referenced in Smittydogs v. Moneyball, 1 F.J. 32, 34 (June 2010), the dichotomy between the Smittydogs and 2 Louns Crew’s motivations is precisely why the Court must look at trades in keeper leagues differently than non-keeper leagues.  However, had this trade been made in a non-keeper league, the Court would approve it. 

Based on the foregoing reasons, the Court hereby decides that the subject trade is fair, equal, and free of collusion.  The trade should be approved as it comports with the best interests of the league.


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