Carson City Cocks vs. Smittydogs – 4 F.J. 229 (September 2012) – Fantasy Baseball Trade Review (L.Lynn/J.Garcia/J/Werth)


Carson City Cocks vs. Smittydogs


Decided September 1, 2012
Cite as 4 F.J. 229 (September 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 Carson City Cocks have made a trade with the Smittydogs.  The Carson City Cocks traded Lance Lynn (SP-STL, $0.40 in the first year of his existing contract) and Stephen Lombardozzi (2B-WAS, $1.00 in the first year of his existing contract) to the Smittydogs in exchange for Jaime Garcia (SP-STL, $1.20 with one year remaining on his existing contract) and Jayson Werth (OF-WAS, $3.00 with one year remaining on his existing contract).

Issue Presented

(1)   Should the trade between the Carson City Cocks and the Smittydogs 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 Lance Lynn and Stephen Lombardozzi in exchange for Jaime Garcia and Jayson Werth looks fair and equitable.  None of the players involved in this deal are considered elite for purposes of requiring additional scrutiny merely because of how valuable they are based on their statistics and name recognition  See Steelers vs. Patriots, 3 F.J. 216, 220 (November 2011).  However, several of these players are stars with significant value.

The Carson City Cocks, once comfortably in 1st place with a 6.5 point lead, are now in 2nd place 2.5 points out of the lead.  Other teams in the league have made drastic improvements to their teams down the stretch of the season, so the Carson City Cocks are looking to do the same.  The additions of Jaime Garcia and Jayson Werth provide upgrades over Stephen Lombardozzi and Lance Lynn. 

Garcia could be a great pickup if he can regain the form that made him one of the better pitchers in the National League before his arm injury earlier this season.  Since being activated from the 60-day disabled list, Garcia has struggled badly over his last two starts.  The Cardinals are in a pennant race so they will need Garcia to pitch well, which should be a motivating factor for him to straighten things out.  When healthy, Garcia is a solid fantasy option.

In comparison, Lance Lynn has been relegated to the Cardinals bullpen after getting hammered over his last several starts.  Perhaps the number of innings he has thrown this year caught up to him as he hit a wall after earning his 13th win earlier this season.  Lynn should be back in the rotation at some point, but his value took a major plunge with this demotion.

Lombardozzi is the type of player that is very valuable for a major league team, but has significantly less value on a fantasy team.  He is eligible to play multiple positions such as second base, third base and outfield.  However, he does not hit with any power and doesn’t provide run production. 

Werth returned from an extended absence due to a fractured wrist and has hit for a good average but hasn’t provided the power or speed he was once known for.  Despite his lack of power, Werth is still is a viable fantasy option and an upgrade over Lombardozzi.  Werth will see regular at bats and at least has the talent to put up numbers that are reminiscent of his recent past.

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 makes sense for both teams.  The Carson City Cocks certainly improve their team by acquiring Garcia in exchange for Lynn who is no longer starting.  In addition, Werth provides a much needed boost to their outfield 

On the other hand, the Smittydogs are clearly in rebuilding mode as they look to the future.  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.  See Winners v. Seven Shades of Shite, 3 F.J. 97, 102 (July 2011).  Both Garcia and Werth only had one more year remaining on their respective contracts.  In return, the Smittydogs obtained Lynn at only $0.40 with two years left on the contract.  Assuming his recent struggles are due more to fatigue than injury, he should be able to replicate his impressive first half performance next year.  Lombardozzi is a classic utility player who can fill a temporary void at almost any position.

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).  As previously discussed, the trade makes the Carson City Cocks better by adding Garcia to a pitching staff that also recently obtained Josh Johnson and Edinson Volquez.  The Smittydogs acquired Lance Lynn who can be a great value next season.  They also obtained $2.80 in salary cap flexibility which could be very useful for making additional moves in their rebuilding process.

This deal epitomizes trades that are made in keeper leagues where teams decide to either compete for the current season or look to build for the future.  The value of the players involved is commensurate with both teams’ needs.  Based on the foregoing reasons, the Court hereby decides that the subject trade should be approved as it comports with the best interests of the league. 


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