Stud Muffins vs. Moneyball – 6 F.J. 226 (June 4, 2014) – Fantasy Baseball Trade Review (T.Tulowitzki/M.Cuddyer/O.Taveras)

SUPREME COURT OF FANTASY JUDGMENT

Stud Muffins vs. Moneyball

ON PETITION FOR WRIT OF CERTIORARI FROM
THE INCONTINENT LEAGUE

Decided June 4, 2014
Cite as 6 F.J. 226 (June 2014)

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 Stud Muffins traded Troy Tulowitzki (SS-COL, $4.40 in the final year of his existing contract and will be entered back in the draft in 2015), Michael Cuddyer (OF-COL, $2.00 in the second year of his existing contract with one year remaining) and Josh Beckett (SP-LAD, $0.40 in the first year of his existing contract with two years remaining) to Moneyball in exchange for Oscar Taveras (OF-STL, $0.50 and can be kept for the next three years at that salary), Carlos Martinez (RP-STL, $0.50 in the second year of his existing contract with one year remaining), Chone Figgins (3B-LAD, $1.00 in the first year of his existing contract with two years remaining), Dan Uggla (2B-ATL, $1.50 in the second year of his existing contract with one year remaining) and Robert Stephenson (SP-CIN, $0.50 in the minor leagues).

Issue Presented

(1)   Should the trade between the Stud Muffins and Moneyball 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.

The IL 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 Troy Tulowitzki, Michael Cuddyer and Josh Beckett in exchange for Oscar Taveras, Carlos Martinez, Chone Figgins, Dan Uggla and Robert Stephenson does not look equitable in terms of present-day value.  Tulowitzki is considered elite for purposes of requiring additional scrutiny merely because of his inherent value and statistical production.  See Steelers vs. Patriots, 3 F.J. 216, 220 (November 2011).

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).

The Stud Muffins are currently in 9th place.  It appears that they are planning for the future by entering into this deal.  When a GM in a keeper league no longer has any hope for contending in the current season, he/she must make a critical roster management decision of whether to trade off established players in exchange for building towards the future.  See Winners vs. Seven Shades of Shite, 3 F.J. 97, 102 (July 2011).

Tulowitzki is unquestionably the best shortstop in fantasy baseball, let alone in this NL-only league.  However, his contract is expiring at the end of the season so the Stud Muffins were going to lose him anyway.  It makes perfect sense that they would want to obtain some form of compensation rather than lose him for nothing.  In addition to the elite shortstop, Moneyball is also acquiring a solid outfielder in Cuddyer and a rejuvenated Josh Beckett.  Under no circumstances can we conclude that the compensation provided by Moneyball is equitable based on present-day value.  Taveras was just called up from the minor leagues last week, Martinez is a middle reliever, Stephenson is still in the minor leagues and likely will not be promoted this year, and Figgins and Uggla are bench players who offer extremely limited production.

Because the IL is a keeper league, we must take into consideration the dichotomy that exists between teams headed in opposite directions in the standings.  We can surmise that Moneyball is looking to make a run for one of the prize winning slots and is employing a “win now” mentality by acquiring Tulowitzki’s expiring contract.  The price he is paying is essentially mortgaging the future by trading away valuable commodities such as Taveras, Martinez and Stephenson.  These three young players are the inexpensive and valuable assets that the Stud Muffins will rely on as they build for the future.

Taveras was recently called up to the Cardinals and has already made an impact.  He has the potential to be a star player.  Martinez is currently pitching in the bullpen, but it is likely that he will be moved into the starting rotation at some point down the road.  He is projected to be the next in the Cardinals long line of successful young starting pitchers who made that transition.  Finally, Stephenson is one of Cincinnati’s top pitching prospects and is not that far away from an eventual promotion.

The trade makes sense from both GM’s perspectives and satisfies their respective goals based on where they are heading in the standings.  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).  The deal epitomizes the motivations of teams with competing interests in a keeper league and both sides have exchanged equitable compensation based on that dichotomy.  Based on the foregoing, the Court approves the trade between the Stud Muffins and the Moneyball.

IT IS SO ORDERED.

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