Smittydogs vs. 2 Louns Crew – 4 F.J. 141 (July 2012) – Revised Fantasy Baseball Trade (R.Braun/J.Santana/B.Jackson)

SUPREME COURT OF FANTASY JUDGMENT

Smittydogs vs. 2 Louns Crew 

ON PETITION FOR WRIT OF CERTIORARI FROM THE INCONTINENT LEAGUE

Decided July 19, 2012

Cite as 4 F.J. 141 (July 2012)

Factual Background

A rotisserie fantasy baseball league called The Incontinent League (hereinafter referred to as “roto league” or “IL” is an 11-team NL-only keeper league utilizing an auction-style draft and transaction platform.  Teams are permitted to maintain up to ten (10) players during each off-season with individual players allowed to be kept for a maximum of three (3) consecutive years under contract.  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 $26.00 draft salary cap, as well as a $36.00 in-season salary cap that is applicable for all teams.   

As with many rotisserie leagues, the Incontinent 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.

The Incontinent League submitted a proposed trade between two league members and seeks an opinion on whether the trade should be approved.

Procedural History

The Smittydogs made a trade with the 2 Louns Crew.  The Smittydogs traded Ryan Braun (OF-MIL, $4.40 with one year remaining on his existing contract), Aramis Ramirez (3B-MIL, $2.30, with one year remaining on his existing contract), Rafael Furcal (SS-STL, $0.80 in the final year of his existing contract), and Johan Santana (SP-NYM, $0.60 in the first year of his existing contract) to 2 Louns Crew in exchange for Allen Craig (OF-STL, $0.60 in the first year of his existing contract), Bryan LaHair (1B/OF-CHC, $0.70 in the first year of his existing contract), Jonathan Hererra (2B-COL, $1.00 in the first year of his existing contract), Darwin Barney (2B-CHC, $0.90 in the first year of his existing contract), Brett Jackson (OF-CHC, $0.50 in the minor leagues and under team control at this salary until he is promoted to the big leagues), Tyler Thornburg (SP-MIL, $0.50 after just being promoted to the big leagues), and Henry Rodriguez ($0.10 in the first year of his existing contract).

This trade is on the heels of these two teams previously attempting to make a trade involving Ryan Braun, Aramis Ramirez and Rafael Furcal in exchange for Allen Craig, Bryan LaHair, Darwin Barney and Jonathan Herrera.  The Court rejected that trade.  See Smittydogs vs. 2 Louns Crew, 4 F.J. 134 (July 2012)..

Issue Presented

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

Decision

The Supreme Court of Fantasy Judgment typically favors individual fantasy sports participants and teams’ ability to make moves, transactions, and trades.  People pay money to participate in fantasy leagues, and generally they should be afforded the freedom to manage their team accordingly.  Whether success is bred from that individual’s decision-making is purely left to some skill, luck, dedication, and savviness.  See 4 Ponies v. Carson City Cocks, 3 F.J. 13 (May 2011).

It is well documented that there is a different analysis of trades in a keeper league as opposed to a non-keeper league.  A trade that may look facially uneven or lopsided could easily pass muster in a keeper league.  Trades made between teams in a keeper league need to be analyzed by other factors besides merely comparing statistics.  Grave Diggers vs. Chilidogs, 4 F.J. 5, 8 (January 2012).  These other factors include salary cap flexibility, contractual status of players, and long-term planning at the expense of the current season.  Smittydogs vs. Moneyball, 1 F.J. 32, 33 (June 2010); Winners vs. Seven Shades of Shite, 3 F.J. 97, 102 (July 2011) (holding that team owners in keeper leagues with no hope of contending in the current season must make critical roster management decisions of whether to trade established players to help build for the future).

The Court will evaluate the objective merits of a deal and ensure that the integrity of the league is maintained.  See Victoria’s Secret vs. C-Train, 2 F.J. 32, 35 (October 2010).  The Court will not undermine a fantasy owner’s ability to manage his/her team unless a deal is unfair or inequitable, ripe with collusion, or not in the best interests of the league.  Whether a trade is objectively   intelligent or popular will not be part of the analysis.  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.

At first glance, the trade of Ryan Braun, Aramis Ramirez, Rafael Furcal and Johan Santana in exchange for Allen Craig, Bryan LaHair, Jonathan Herrera, Darwin Barney, Brett Jackson, Tyler Thornburg and Henry Rodriguez does not look equitable.  Braun is the only player in this trade considered elite for the purposes of requiring additional scrutiny merely because of how valuable he is by name recognition, reputation, and performance.  Steelers vs. Patriots, 3 F.J. 216, 220 (November 2011).  Coming off a controversial MVP season, Braun is putting up MVP-type numbers once again.  Through July 18, 2012, he is batting .309 with 26 homeruns, 65 RBI, 61 runs scored, and 16 stolen bases.  As stated in the analysis of the previous trade, Braun’s performance is even more impressive when you consider the fact Prince Fielder is no longer providing protection for him in the Brewers’ lineup.  Smittydogs vs. 2 Louns Crew, 4 F.J. at 136.

Despite being slowed by a lingering groin injury, Braun is one of the few true five-category fantasy baseball players.  His inclusion in a trade would require significant compensation in the opposing package.  However, the additions of Aramis Ramirez, Rafael Furcal and now Johan Santana along with Braun exponentially increase the value of any package that would need to be provided. 

The Court previously did a statistical analysis and comparison of the prior trade, so for judicial economy we will not engage in a similar analysis merely a few days later.  Nothing substantively has changed in terms of the players’ statistics to necessitate revisiting the inequity of the initial trade.  The analysis of this case hinges on whether the additions of Santana, Jackson, Thornburg and Rodriguez make the trade fair and equitable in the best interests of the league overall.

Johan Santana, once regarded as an elite fantasy pitcher, has made a remarkable comeback from serious shoulder surgery which caused him to miss the entire 2011 season.  Thus far, he compiled six wins, including a no-hitter, to go along with a 3.59 ERA, 1.20 WHIP, and 102 strikeouts in 107 innings.  Despite having some great success in a handful of games, including his no-hitter and a previous shutout, Santana has been mostly a pedestrian pitcher this season.  His latest trends are not good as he given up 13 runs in his past two starts.  He has failed to make it past six innings in six of his last seven starts.  On top of that, the Mets bullpen is the worst in the league so any game he does not complete has a significant chance of costing him a win.

That being said, Santana is still a decent fantasy pitcher who will help more than hurt a team in any roto category.

In exchange, 2 Louns Crew has added Brett Jackson, Tyler Thornburg and Henry Rodriguez to the deal.  Thornburg was recently recalled by Milwaukee to fill in for Zack Greinke who has missed some time.  In his two starts, Thornburg has given up seven homeruns in 12 innings of work while compiling a 6.00 ERA and 1.58 WHIP.  When Greinke comes back, Thornburg will likely end up in the bullpen or be sent back down to the minors.  He does have some value long-term as he is projected to be in the rotation by 2013.  However, if the Brewers do trade Greinke, Thornburg will likely be given a chance to stay in the rotation.

Brett Jackson is the Cubs #1 prospect in their organization, as well as one of the top offensive prospects in baseball.  The Cubs may look to promote him after making some trades later in the summer.  He possesses a combination of power and speed which will be very valuable in keeper leagues.  Henry Rodriguez had been the Nationals’ closer earlier in the season before blowing 25% of his save opportunities.  He has an overpowering fastball but lacks command of his stuff at this juncture.  After being activated from the disabled list, Rodriguez will be one of Washington’s primary set-up men.  He does have closer potential down the road, but he first must learn how to pitch rather than throw.

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).  It is clear that 2 Louns Crew, now in 5th place, is looking to make a run for this season.  The additions of Braun, Ramirez, Furcal and Santana will be a huge boost in all offensive and pitching categories.

The Smittydogs, currently in 10th place, appear to be punting the current season.  When a team owner in a keeper league no longer has any hope for contending in the current season, he must make a critical roster management decision of whether to trade off established players in an attempt to build for the future.  See Winners v. Seven Shades of Shite, 3 F.J. 97, 102 (July 2011).  The Court understands why the Smittydogs are inclined to trade away expensive stars like Braun and Ramirez, as well as an expiring contract with Furcal.  While the Court failed to see any cognizable short-term or long-term benefit from the original players he was acquiring, this revised package does have projected value.

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.  Los Pollos Hermanos v. Little Stumps, 3 F.J. 192, 195 (October 2011).  The trade unequivocally would make 2 Louns Crew better by adding Braun, Ramirez and Furcal to his lineup, as well as Santana to his pitching staff.  They do not lose or downgrade anything in terms of present-day value by trading away Craig, LaHair, Herrera, Barney, Rodriguez, Jackson or Thornburg.  On the other hand, while the Smittydogs clearly suffer significant downgrades up and down their current roster, they at least are acquiring valuable commodities which can make them better in the long run. 

In the initial trade, Allen Craig was the best player being obtained by the Smittydogs.  He at least will provide a production with power and batting average.  However, now the Smittydogs are also adding a minor league outfield prospect and a pitching prospect who will very likely play in 2013.  Rodriguez has impressive stuff and can be a closer if given the opportunity. 

In terms of the contractual and financial ramifications of the trade, the Smittydogs will be netting an additional $3.90 of salary.  This is a significant amount as it represents 11% of the permitted in-season salary cap.  The Smittydogs can use this additional money to make other transactions in support of his rebuilding for the future. 

The Court has no issues with the idea of trading superstar players so long as the package in return is equitable and makes sense given the needs of both teams.  4 Ponies v. Beaver Hunters, 3 F.J. 26, 29 (June 2011).  While the initial trade lacked any potential future value, this revised trade does offer compensable benefits to a team choosing to build for next year.  Clearly this trade is uneven in terms of present-day value, but it is fair enough to warrant approval in furtherance of the goals of fantasy baseball teams playing in keeper leagues.  Based on the foregoing reasons, the Court hereby decides that this revised trade should be approved.  

IT IS SO ORDERED.

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