Polcats vs. Carson City Cocks – 5 F.J. 103 (July 15, 2013) – Fantasy Baseball Trade Review (N.Eovaldi/A.Eaton)

SUPREME COURT OF FANTASY JUDGMENT

Polcats vs. Carson City Cocks

ON PETITION FOR WRIT OF CERTIORARI FROM
THE INCONTINENT LEAGUE

Decided July 15, 2013
Cite as 5 F.J. 103 (July 2013)

Factual Background

A rotisserie fantasy baseball league called The Incontinent League (hereinafter referred to as “roto league” or “IL” is a 12-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’s commissioner submitted a proposed trade between two league members and seeks an opinion on whether the trade should be approved.

Procedural History

The Polcats traded Nathan Eovaldi (SP-MIA, $0.10 in the first year of his existing contract with two years remaining) to the Carson City Cocks in exchange for Adam Eaton (OF-ARZ, $0.50 in the first year of his existing contract with two years remaining).

Issue Presented

(1)   Should the trade between the Polcats and the Carson City Cocks be approved?

Decision

The Court has consistently ruled that people who participate in fantasy leagues should be given the freedom to manage their teams according to their own preferences.  Whether success is bred from that individual’s decision-making is purely left to some skill, luck, dedication, and savviness.  See Gangrene Master Yoda vs. Team Dizzle, 4 F.J. 284, 285 (October 2012); 4 Ponies vs. Carson City Cocks, 3 F.J. 13 (May 2011).

When presented with a dispute over the fairness or equitability of a trade, 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).  Typically, the approval or rejection of a trade is based on whether the deal was made without collusion, has equitable consideration, and comports with the best interests of the league.  See 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 Nathan Eovaldi in exchange for Adam Eaton looks fair and equitable.  Neither player involved in this trade is considered elite for purposes of requiring additional scrutiny.  See Steelers vs. Patriots, 3 F.J. 216, 220 (November 2011).

The Incontinent League is a keeper league which can lead to a different evaluation of a trade as opposed to a non-keeper or redraft 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).

This trade represents two young players with upside being exchanged for each other.  Eaton just made his season debut this past week after recovering from an elbow injury.  He should start to become an everyday player once he gets his timing back and can be highly productive in terms of runs scored and stolen bases.  Eovaldi was one of the primary players acquired by the Marlins when they traded Hanley Ramirez to the Dodgers in 2012.  He has been a pitching prospect for a few years now and looks like he will be a fixture in Miami’s rotation going forward.  Since returning from an injury, Eovaldi has gone 2-0 with a 2.93 in five starts.

Both players are in the first years of their respective contracts and have inexpensive salaries.  The Polcats have made several trades this year positioning them to compete for next year and beyond.  They have accumulated an impressive nucleus of starting pitchers including Matt Harvey, Shelby Miller. Tony Cingrani and Tyler Skaggs.  Because of that, Eovaldi was expendable and they were able to obtain a solid young outfielder who can provide production in multiple categories.

In addition, the Carson City Cocks, currently in 3rd place and only three points out of 1st place, had an immediate need for a starting pitcher due to a rash of injuries sustained by his staff.  Both of these players satisfy the respective needs of each team and present fair and equitable compensation for one another.  Based on the foregoing, the Court approves the trade between the Polcats and the Carson City Cocks.

IT IS SO ORDERED.

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