Victoria’s Secret vs. NY Cowboys – 6 F.J. 149 (May 20, 2014) – Fantasy Baseball Trade Review (A.McCutchen/M.Byrd/C.Maybin)


Victoria’s Secret vs. NY Cowboys


Decided May 20, 2014
Cite as 6 F.J. 149 (May 2014)

Factual Background

A rotisserie fantasy baseball league (hereinafter referred to as “roto league” or “The Angerthal League”) that was formed in 1988 and utilized an auction-style draft seeks an evaluation of a trade made between two teams.  This is a twelve-team NL-only keeper league where each team has a $260.00 salary cap to draft 23 players.  During the season, there is no limitation on players’ salaries.  Teams are permitted to retain between 7-15 players during each off-season with each individual player allowed to be kept for three years before they must either be signed to a long-term contract (“LTC”), play, or be returned to the free agent pool.

Players with a LTC have a progressive salary structure of (Base Salary + ((N-1) * 5)) where N = the number of years a team wants to sign the player. Once a player is signed to a LTC, there is a real monetary penalty (which depends on the structure of the salary of the player – if the salary is less than $10, then there is a penalty of $20; or there is a penalty of two times the player’s salary if he is released early from a LTC). All money collected for penalties is placed into the pool for prize money.  After a LTC is completed, the player is not eligible to be signed again and must be placed back into the free agent pool for the next season’s draft. Teams that finish in 1st through 4th place in the Roto League will win money prizes at the end of each season.

As with many rotisserie leagues, the Angerthal 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.

Procedural History

On May 14, 2014, Victoria’s Secret traded Andrew McCutchen (OF-PIT, $35.00 in the second year of his existing contract) and Chase Headley (3B-SD, $17.00 in the final year of his existing contract) to the NY Cowboys in exchange for Marlon Byrd (OF-PHI, $1.00 in the second year of his existing contract) and Cameron Maybin (OF-SD, $7.00 in the first year of his existing contract).

Pursuant to a challenge by a team known as The Specialists, the Angerthal League commissioner has submitted this trade to the Court for review to determine whether it should be approved or rejected.  No specific reason was provided by The Specialists as the basis for the challenge.

Issue Presented

(1)        Should the trade between Victoria’s Secret and the NY Cowboys be approved?


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.

The Angerthal 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).

At first glance, the trade of Andrew McCutchen and Chase Headley in exchange for Marlon Byrd and Cameron Maybin does not look fair and equitable.  McCutchen, the reigning National League MVP, is considered elite for purposes of requiring additional scrutiny merely because of how valuable he is.  Steelers vs. Patriots, 3 F.J. 216, 220 (November 2011).  The Court has no issues with the idea of trading superstar players so long as the package in return is equitable and makes sense given the needs of both teams.  See 4 Ponies vs. Beaver Hunters, 3 F.J. 26, 29 (June 2011).

Victoria’s Secret is currently in 11th place and 9.5 points behind the 10th place team.  In the case submission, Victoria’s Secret provided the following reasoning and rationale behind making this deal:

“Clearly the stars and scrubs approach is not working for my club.  I am adapting a spread the risk approach and getting two inexpensive, everyday players that I can keep seemed like a good start.”

This reasoning epitomizes the thought process for GM’s in a keeper league that no longer has any hope for contending in the current season.  He/she must make critical roster management decisions of whether to trade off established players in exchange for less expensive entities in building for the future.  See Winners vs. Seven Shades of Shite, 3 F.J. at 102.

Despite the fact that it is only Week 8 of the fantasy baseball season and we have not even reached Memorial Day, it is still within Victoria’s Secret’s discretion to make the realistic determination of his own team’s fate for the rest of the season.  By virtue of making this trade with the NY Cowboys who are currently in 2nd place, the dichotomy of keeper league trade strategy has been exemplified given the competing interests of one team in a “win now” mentality coupled with a trade partner looking to build for the future by trading away expensive assets.  Knights vs. Seawolves, 5 F.J. 46, 48 (May 2013).

Clearly McCutchen is the best player in this trade, so we must ensure that the compensation being provided to Victoria’s Secret is fair and equitable under the circumstances.  Currently McCutchen is batting .301 with four home runs, 19 RBI, 21 runs scored and six stolen bases.  While he provides solid production in all five roto categories, he has only averaged 25 home runs and 90 RBI along with a .301 batting average over the past three seasons.  We do not mean not undermine or minimize McCutchen’s talent or accomplishments, but we must also be realistic about his statistical production especially when compared to other elite level players.

The addition of Chase Headley to the package makes perfect sense from Victoria’s Secret’s perspective because he is in the last year of his contract and would become eligible for the league’s draft in 2015.  Rather than lose him for nothing, Victoria’s Secret was able to dump his salary in the trade and obtain compensation for a hitter only batting .189 with four home runs, 13 RBI, 10 runs scored, one stolen base, and living off the hype of one half of a season a few years ago..

In return for McCutchen and Headley, Victoria’s Secret has acquired Marlon Byrd and Cameron Maybin.  Byrd experienced a career renaissance in 2013 and parlayed that into a lucrative contract with the Phillies.  He has not disappointed thus far by batting .295 with five home runs, 25 RBI, and 15 runs scored.  These numbers are similar to McCutchen’s minus the stolen bases.  That isn’t to say that Byrd has equal value to McCutchen.  But it cannot be denied that statistically Byrd is capable of matching McCutchen’s production for the remainder of this season (with the exception of stolen bases) and perhaps next year when both of their respective contracts expire after 2015.

The addition of Cameron Maybin to the deal is intriguing due in large part to the tremendous talent he possesses.  However, it cannot be denied that Maybin is an injury risk and has been an overall bust throughout his career.  Since coming back from an injury, Maybin is batting .280 with no home runs, no RBI, seven runs scored and one stolen base in 57 at bats.  While he does have the potential to break out, fantasy GM’s should not hold their collective breaths waiting for that to happen.

This trade unquestionably makes the NY Cowboys better and increases their chances for competing for the league championship.  They have taken on an expensive $35.00 contract in McCutchen as well as Headley’s expiring $17.00 contract.  On the other hand, Victoria’s Secret obtains $44.00 of salary cap relief by making this trade and allows them to revamp their approach either for the rest of 2014 or in preparation for 2015 since both Byrd and Maybin can be retained as they still have another year remaining on their contracts.

Typically the only circumstances where we will reject a trade are: 1) if the deal is made in violation of league rules; 2) if the deal is made through collusion; 3) the deal is so grossly lopsided that is has a detrimental effect on the whole league; and 4) if the deal makes absolutely no sense and/or fails to improve at least one of the team’s rosters in any capacity.  Grand Theft Votto vs. That Wimpy Deer, 6 F.J. 39, 42 (April 2014).  The two areas of concern in evaluating this trade are numbers three and four.  However, we don’t view this trade as being grossly lopsided to the point where it has a detrimental effect on the league.  The balance of the trade would appear to favor the NY Cowboys, but that does not create an imbalance which requires intervention.  In addition, the deal does provide Victoria’s Secret with salary cap relief and furthers their renewed strategy of having a more balanced team.  Based on the foregoing, the Court approves this trade between Victoria’s Secret and the NY Cowboys.


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