Smittydogs vs. 2 Louns Crew – 4 F.J. 155 (July 2012) – Fantasy Baseball Trade Review (J.Santana/E.Jackson)


Smittydogs vs. 2 Louns Crew


Decided July 27, 2012

Cite as 4 F.J. 155 (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 Edwin Jackson (SP-WAS, $2.10 with one year remaining on his existing contract) to 2 Louns Crew in exchange Johan Santana (SP-NYM, $0.60 with two years remaining on his existing contract).

Issue Presented

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


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 Edwin Jackson in exchange for Johan Santana looks fair and even.  Neither pitcher is considered elite for the purposes of requiring additional scrutiny merely because of how valuable they are by name recognition, reputation, and performance.  Steelers vs. Patriots, 3 F.J. 216, 220 (November 2011). 

Even though this deal was made while Santana is on the disabled list, it does not tip the scale in either direction of the analysis.  If Santana was sidelined because of recurring shoulder problems stemming from his surgery, that could be a determining factor.  However, Santana sustained an ankle injury a few weeks ago and was placed on the disabled list as a means for him to get some additional rest.  He is scheduled to return from the DL when he is eligible and pitch August 8 or 9 against Miami.  See  As a result, the Court will evaluate him with the presumption that he will pitch over the final two months of the season.

After missing the entire 2011 season, Santana returned and has had mixed results.  Thus far, he compiled six wins, including a no-hitter, to go along with a 3.98 ERA, 1.27 WHIP, and 105 strikeouts in 110.2 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 19 runs in his past three starts – all losses where he failed to pitch past the fifth inning.  That being said, Santana is still a decent fantasy pitcher who can help more than hurt a team in any roto category.

Edwin Jackson has very similar statistics to Santana.  Through July 26, 2012, Jackson is 6-6 with a 3.52 ERA, 1.15 WHIP, and 90 strikeouts in 120.1 innings.  Jackson, a historically inconsistent pitcher with lots of raw talent, has benefited from pitching in a pitcher-friendly ballpark in Washington and also has the luxury of having one of the league’s best bullpens behind him.  With the Nationals in first place, Jackson will be pitching in the heart of a pennant race which should keep him focused and motivated.  Additionally, he will be a free agent at the end of the season which is always a motivating factor for players.

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 7th place, is still looking to make a run for this season.  After having previously acquired Santana from the Smittydogs, they are understandably concerned about what production can be expected for the rest of this season.  See Smittydogs vs. 2 Louns Crew 4 F.J. 141 (July 2012).  Jackson provides an upgrade right now which furthers 2 Louns Crew’s goals. 

The Smittydogs, still in 10th place, have already punted 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).  They are reacquiring Santana who they will have contractual control over for another two years at only $0.60.  Further, the Smittydogs net $1.50 in salary cap flexibility which can be used for additional roster moves.

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).  This trade makes logical sense from both teams’ perspectives and furthers each of their respective goals.    

Based on the foregoing reasons, the Court hereby decides that this trade should be approved as it comports with the best interests of the league.  


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