Polcats vs. 4 Ponies – 5 F.J. 21 (April 17, 2012) – Fantasy Baseball Trade (S.Strasburg/S.Miller/N.Syndergaard)

SUPREME COURT OF FANTASY JUDGMENT

Polcats vs. 4 Ponies

ON PETITION FOR WRIT OF CERTIORARI FROM
THE INCONTINENT LEAGUE

Decided April 17, 2013
Cite as 5 F.J. 21 (April 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 Incontinent League previously had 11 teams during the 2012 season.  Entering the 2013 season, the league added a 12th team known as the Polcats.  To help build their franchise, the Polcats were able to keep one player from each of the 11 other teams after their initial ten keepers were claimed.

The Polcats traded Stephen Strasburg (SP-WAS, $4.40 in the first year of his existing contract with two years remaining) to the 4 Ponies in exchange for Shelby Miller (SP-STL, $0.50 in the first year of his existing contract with two years remaining), Drew Storen (RP-WAS, $0.70 in the first year of his existing contract with two years remaining), and Noah Syndergaard (SP-NYM, $0.50 in the minor leagues).

Issue Presented

(1)   Should the trade between the Polcats and the 4 Ponies 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 Stephen Strasburg in exchange for Shelby Miller, Drew Storen and Noah Syndergaard looks inequitable.  Strasburg is an elite fantasy pitcher which would require additional scrutiny in a trade because of how valuable he is.  See Steelers vs. Patriots, 3 F.J. 216, 220 (November 2011).  Given that the Incontinent League is NL-only, Strasburg was arguably the second best starting pitcher behind Clayton Kershaw entering the 2013 season.

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).

We must take into consideration the fact that the Polcats just joined the league and were allowed to build their roster by selecting players to keep from each of the other 11 teams after those teams claimed their respective keepers.  As a brand new franchise, it is reasonable for the Polcats to try and build their team to sustain success in the future and no