Stud Muffins vs. Nub Vader – 3 F.J. 34 (June 8, 2011) – fantasy baseball trade (S.Castro/I.Desmond)

SUPREME COURT OF FANTASY JUDGMENT

Stud Muffins vs. Nub Vader

ON PETITION FOR WRIT OF CERTIORARI FROM THE INCONTINENT LEAGUE 

Decided June 8, 2011

Cite as 3 F.J. 34 (June 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 Stud Muffins have made a trade with Nub Vader.  The Stud Muffins traded Starlin Castro (SS-CHC), Matt Lindstrom (RP-COL), and Wilson Ramos (C-WAS) to Nub Vader in exchange for Ian Desmond (SS-WAS), Koyie Hill (C-CHC), and Ricky Nolasco (SP-FLA).

Issue Presented

(1)   Should the trade between the Stud Muffins and Nub Vader 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. 

The Court has always held that the approval or rejection of a trade is based purely on its fairness, free from collusion, and in the best interests of the league.  Whether a trade is intelligent or popular will not be part of the analysis.  The virtue of a trade is measured in both quantifiable criteria and subjective needs of the teams involved.  See Carson City Cocks v. Stud Muffins, 3 F.J. 23, 24 (May 2011).

At first glance, the trade of Starlin Castro, Matt Lindstrom, and Wilson Ramos in exchange for Ian Desmond, Koyie Hill and Ricky Nolasco looks fair.  None of the players involved can objectively be considered stars, so there is no need to analyze whether the trade “shocks the conscience” as it would have had the trade included a player such as Albert Pujols or Roy Halladay.  None of the offensive players in the trade will contribute much in terms of homeruns and RBI.  Castro and Desmond are respectable options at shortstop and each will contribute in terms of runs and stolen bases.  Ramos is by far a better hitter than Hill, who is a career backup and has only received playing time with the Cubs due to Geovany Soto’s struggles.  Ramos is the primary catcher in Washington and has shown some ability to handle the bat.  He was a highly touted prospect with the Twins and was acquired in 2010 in exchange for Matt Capps.  Ramos will get every opportunity to play and learn from his backup, Ivan Rodriguez.  Nolasco has never fulfilled his potential since a breakout season a couple years ago when he nearly struck out 200 batters.  He is still a solid starting pitcher to round out a staff.  Lindstrom is a setup relief pitcher and will only get saves when Rockies’ closer Huston Street needs a rest or is injured.  His ERA and WHIP have been impressive as he looks like he finally learned how to pitch instead of just throwing 100 mph fastballs. 

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 at issue involves a pitcher, catcher and shortstop on both sides.  As a result, there is no need to do a positional analysis of either team because the exchange is exact (except for the fact Lindstrom is a relief pitcher and Nolasco is a starting pitcher).  The Court does note that it is peculiar as to why Nub Vader, the 11th place team, would trade off Nolasco in exchange for Lindstrom when starting pitching is clearly a weakness of his.  The exchange is fair, but the Court recognizes the disconnect between the trade and the more prevailing needs of a team at the bottom of the standings.

Statistically, the trade favors Nub Vader on offense.  In contrast, the Stud Muffins are getting the better pitcher in Nolasco who will contribute wins and strikeouts where Lindstrom cannot.  The statistical comparison of the players is provided below:

Player

AVG.

HR

RBI

Runs

SB

Starlin Castro

.301

1

26

31

5

Wilson Ramos

.254

4

17

19

0

 

 

 

 

 

 

Ian Desmond

.229

3

17

26

18

Koyie Hill

.215

1

7

11

0

 

 

 

 

 

 

Player

Wins

ERA

K’s

WHIP

Saves

Matt Lindstrom

0

1.48

17

1.02

2

Ricky Nolasco

4

3.99

65

1.30

0

Based on the statistical comparison of the players involved, the numbers are close enough to preclude the need for any deeper performance analysis.

In terms of keeper league status and salary cap value, this trade does not raise any red flags regarding a large disparity in salary cap value or keeper league contract status.  Nub Vader will acquire $1.00 in salary cap room by making the trade and will have Ramos for two more years and Castro for one more.  In contrast, the Stud Muffins will have the rights to Nolasco for another two years.   

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

It should be reiterated that the Court typically favors a league owner’s ability to make trades and manager the roster according to his/her own preferences and judgments.  When a person pays money to participate in a fantasy league, the presumption is that he/she is permitted to make whatever decisions they feel are best for their team.  Based on the foregoing reasons, the Court hereby decides that the subject trade is fair and even.  The trade should be approved as it comports with the best interests of the league.

IT IS SO ORDERED.

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