Bada Bing Boys vs. Lil Nicky – 6 F.J. 219 (June 2, 2014) – Fantasy Baseball Trade Review (Y.Puig/C.Kershaw/J.Ellsbury)


Bada Bing Boys vs. Lil Nicky


Decided June 2, 2014
Cite as 6 F.J. 219 (June 2014)

Factual Background

A rotisserie fantasy baseball league called the Jabroni League (hereinafter referred to as “JL” was established in 1999 and is hosted on CBS.  The JL is a 12-team mixed AL/NL keeper league where teams are permitted to maintain a maximum of six (6) players.  GM’s can either retain players under a one-year contract or a three-year contract.  If a player was acquired during the auction draft, his value escalates $5.00 the following season.  If a player was acquired via free agency, his value escalates $8.00 the following season and then $5.00 every subsequent year capped at three years of keeper eligibility.

The JL uses a standard 5×5 format for its 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.

All trades made between GM’s are subject to review.  Due to the fact that the JL is comprised of several clusters of family members and close relatives, the commissioner has the sole authority to submit all trades to the Court for review to avoid any potential conflicts.

The commissioner has submitted a trade to the Court for review to determine whether it should be approved or rejected.

Procedural History

The Bada Bing Boys traded Yasiel Puig (OF-LAD, can be kept for $13.00 in 2015), Dustin Ackley (2B/OF-SEA, can be kept for $18.00 in 2015), Zach Britton (RP-BAL, can be kept for $8.00 in 2015) and A.J. Burnett (SP-PHI, can be kept for $8.00 in 2015) to Lil Nicky in exchange for Jacoby Ellsbury (OF-NYY, cannot be kept), Clayton Kershaw (SP-LAD, can be kept for $40.00 in 2015) and Steve Cishek (RP-MIA, can be kept for $11.00 in 2015).

Issue Presented

(1)   Should the trade between the Bada Bing Boys and Lil Nicky 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 JL 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 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 Yasiel Puig, Dustin Ackley, Zach Britton and A.J. Burnett in exchange for Jacoby Ellsbury, Clayton Kershaw and Steve Cishek looks fair and equitable.  Puig and Kershaw are considered elite for purposes of requiring additional scrutiny merely because of how valuable they are.  Steelers vs. Patriots, 3 F.J. 216, 220 (November 2011).   The Court does not have an issue with trading superstar players so long as the compensation being exchanged for them is equitable.  Ellsbury has the ability to be an elite fantasy player, but his history of injuries and lack of power keep him from retaining that status.

When a trade such as this is consummated involving the exchange of players at different positions, it can reasonably be concluded that both GM’s have different interests and priorities with respect to the composition of their rosters.  See In Pursuit of the Grail vs. Reloading Again, 6 F.J. 12, 13 (March 2014).  GM’s in roto leagues are free to prioritize which categories they want to pursue improvement in when making trades and managing their rosters.  Team Sabo vs. 4 Ponies, 5 F.J. 167 (August 2013) (approving a trade where a team higher in the standings traded Mat Latos for Homer Bailey because he needed improvement in the WHIP category despite Bailey having better statistics with wins, ERA and strikeouts); Joba’s Mustache vs. Obtuse Wardens, 5 F.J. 40, 41 (May 2013); Stud Muffins vs. Cajun Crawdads, 4 F.J. 61, 63 (May 2012).

Since the record is devoid of any information regarding where either of these teams are in the standings, we can only draw inferences from the trade itself on whether the dichotomy of keeper league trade strategy is being employed.  Knights vs. Seawolves, 5 F.J. 46, 48 (May 2013) (holding that keeper leagues tend to demonstrate a dichotomy in trade strategy where one team is in a “win now” mentality coupled with a trade partner looking to build for the future by trading away expensive assets).  It appears that neither team is conceding the current season as the trade has significant present-day value for both GM’s.

The primary components of this trade are Puig and Kershaw.  Puig has proven that his tremendous rookie season was not a fluke as he is currently batting .346 with 11 home runs, 40, RBI, 32 runs scored and five stolen bases.  He is unquestionably a candidate for National League MVP and is showing no signs of slowing down.  On the other hand, Kershaw, the reigning National league Cy Young winner, is one of the top fantasy pitchers in the league despite missing some time with an injury and having a slightly inflated ERA of 3.56 and a WHIP of 1.21.  While a hitter and pitcher obviously provide different types of production, they are equally valuable and present fair compensation for one another.

It should be noted that Ellsbury cannot be kept in 2015, so it does make sense for Lil Nicky to trade him and get compensation rather than lose him for nothing at the end of the year.  Obtaining Puig more than compensates for the loss of Ellsbury in his outfield.  In addition to Puig, Lil Nicky also obtained Dustin Ackley who qualifies at both second base and outfield.  Ackley started off the year strong, but he has seen his average drop to .238 to go along with four home runs and 19 RBI.  While he is not overly productive, he provides positional flexibility and depth.

In terms of the remaining pitchers in the deal, the value is unquestionably equitable.  Steve Cishek is a more established closer, but Zach Britton has done well since taking over ninth inning responsibilities for the Orioles.  A.J. Burnett’s inclusion more than makes up the difference as he is still a viable fantasy pitcher at the back end of most GM’s pitching staffs.

Even without knowing their rosters or the current standings, this star-studded deal appears to make sense from both teams’ perspectives.  See Los Pollos Hermanos vs. Little Stumps, 3 F.J. 192, 195 (October 2011) (holding that 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).  Both teams received fair and equitable compensation as they pursued their own respective needs in making this trade.  Based on the foregoing, the Court approves the trade between the Bada Bing Boys and Lil Nicky.


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