Stud Muffins vs. Smittydogs – 4 F.J. 54 (May 15, 2012) – Fantasy Baseball Trade Review (Kershaw/J.Santana)


Stud Muffins vs. Smittydogs


Decided May 15, 2012

Cite as 4 F.J. 54 (May 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 Stud Muffins made a trade with the Smittydogs.  The Stud Muffins traded Johan Santana (SP-NYM, $0.50 with one year left on his existing contract), Brett Pill (OF-SF, $0.50 with two years left on his existing contract), and Gary Brown (OF-SF, $0.50 in the minors and under control until he reaches the big leagues) to the Smittydogs in exchange for Clayton Kershaw (SP-LAD, $3.90 with one year left on his existing contract)..

Issue Presented

(1)   Should the trade between the Stud Muffins and the Smittydogs be approved?


The Supreme Court of Fantasy Judgment 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.  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.  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 Johan Santana, Brett Pill and Gary Brown in exchange for Clayton Kershaw does not look equitable.  In this deal, Kershaw is the only player regarded as elite.  As well as Johan Santana has pitched thus far, he is no longer considered an elite fantasy pitcher.  Kershaw is indisputably one of the best fantasy pitchers in baseball, especially in an NL-only league such as the Incontinent League.  Any trade involving premier fantasy players is going to require additional scrutiny merely because of how valuable they are.  See Steelers vs. Patriots, 3 F.J. 216, 220 (November 2011).  In this case, Kershaw, the reigning National League Cy Young winner, is arguably the best starting pitcher in the NL-only Incontinent League (with all due respect to Roy Halladay and a few others).  Santana is coming back from major shoulder surgery that cost him the entire 2011 season.  Even before his injury in late 2010, Santana’s numbers had been in slight decline compared to his seasons inMinnesota as a Cy Young Award winner.  He has pitched well thus far with impressive strikeout totals (41), ERA (2.92) and WHIP (1.16).  However, he does not have the benefit of consistent run support and must rely on an extremely volatile bullpen, both of which will limit the number of wins he can achieve.  It is also unknown whether he will be able to remain healthy let alone continue this level of excellence throughout the course of the season.  Pill is currently a part-time player with the Giants.  He has shown some flashes of power, but it does not appear he will be in line for consistent starts either at first base or in the outfield.  Brown is the Giants top minor league prospect and is still likely a couple years away from making an impact at the major league level.

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 a swap of starting pitchers and one team also acquiring a minor league outfielder and a rookie who qualifies at first base, third base and outfield.  As a result, it does not appear that positional needs were a factor in the parties’ rationale for making the deal.  

It goes without saying why the Stud Muffins would want to acquire Kershaw.  Because Pill and Brown have little to no value for the current season, this is essentially an upgrade from Santana to Kershaw for the 2012 season.  On the other hand, the Smittydogs do fill the void left by Kershaw with Santana despite representing a definitive downgrade regardless of Santana’s early season success.  The Smittydogs already have a plethora of players with similar position eligibility as Pill, so this adds additional depth that can be used for future trades.  Finally, Gary Brown represents the Smittydogs’ attempt to build for the future which is a common rationale for unloading current talent in a keeper league.  Brown is a highly rated prospect and can be under Smittydogs’ control for only $0.50 until he is called up to the big leagues.  From this perspective, it makes sense that the Smittydogs are considering their long-term options

In terms of the contractual and financial ramifications of the trade, it makes sense on both sides.  The Stud Muffins are adding $1.40 to their salary cap in the deal, but Kershaw is a difference-maker and can still be retained another year as per the terms of his current contract.  His acquisition clearly falls in the “win now” mentality for the Stud Muffins.  On the other hand, the Smittydogs do save $1.40 which they can use during the season to continue their long-term rebuilding project.  However, the Smittydogs are currently in 7th place and only 15 points out of 1st place, and just 8.5 points out of one of the payout positions (4th place).  Given that, it does not appear that the Smittydogs are punting the season.  Assuming Santana can stay healthy, the Smittydogs can at least remain competitive while also obtaining the long-term benefits of young players such as Pill and Brown.

Based on the foregoing reasons, the Court hereby decides that the subject trade is fair, equal, and free of collusion.  There is a rational basis for both teams to make this trade with respect to roster management and the teams’ short and long-term goals.  The trade should be approved as it comports with the best interests of the league. 


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