Coming From Behind vs. Miggy is Back – 6 F.J. 258 (June 15, 2014) – Fantasy Baseball Trade Rejected (F.Hernandez/R.Braun/G.Polanco)


Coming From Behind vs. Miggy is Back


Decided June 15, 2014
Cite as 6 F.J. 258 (June 2014)

Factual Background

A rotisserie fantasy baseball league called the College Amigos Fantasy Baseball League (hereinafter referred to as “CAFBL” was established in 1999 and is hosted on CBS.  The CAFBL is a 14-team mixed AL/NL keeper league utilizing an auction-style draft with a budget of $260.00 for 27 players.  Teams are permitted to maintain up to five (5) players during each off-season with players’ salaries increased by $2.00 multiplied by the number of years they have been kept.  The salary of a player acquired in the draft is his auction price.

As with many rotisserie leagues, the CAFBL 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.  The CAFBL applies a head-to-head format where each category is considered a win.

The CAFBL has a written constitution with rules and guidelines in place regarding trades.  The relevant rules pertaining to trades are as follows:

8.     TRADES

8.3   Trades do not affect the salary or contracts of players.
8.4   Trades may only involve players in the instant trade and may not involve cash, players to be named later, or future considerations.


9.1.   Trades shall be referred to a 3rd party reviewer and that decision is final.
9.2    The 3rd party reviewer may consider the contract and salary of players for keeper purposes, but the primary considerations of review shall be preservation of the integrity and overall competitiveness of the current season.

The CAFBL’s commissioner submitted a proposed trade between two league members and seeks an opinion on whether the trade should be approved.

Procedural History

This is an amended trade consummated between these two teams following the Court’s rejection of their previous trade.  Coming From Behind vs. Miggy is Back, 6 F.J. 250 (June 12, 2014) (rejecting the trade of Gregory Polanco, Yangervis Solarte, Yovani Gallardo, and Rick Porcello in exchange for Ryan Braun, Jhonny Peralta, Felix Hernandez and Trevor Rosenthal).

The revised trade is as follows: Coming From Behind traded Gregory Polanco (OF-PIT, $3.00 salary in 2014), Yangervis Solarte (3B-NYY, $5.00 salary in 2014), John Lackey (SP-BOS, $2.00 salary in 2014) and Rick Porcello (SP-DET, $3.00 salary in 2014) to Miggy is Back in exchange for Ryan Braun (OF-MIL, $38.00 salary in 2014), Andrelton Simmons (SS-ATL, $15.00 salary in 2014), Felix Hernandez (SP-SEA, $29.00 salary in 2014) and Trevor Rosenthal (RP-STL, $3.00 salary in 2014),

Issue Presented

(1)   Should the amended trade between Coming From Behind and Miggy is Back be approved?


After the Court previously rejected the prior trade between these teams, Coming From Behind and Miggy is Back have agreed to an amended trade which is now subject for approval.  The only changes made from the prior trade are swapping out Jhonny Peralta for Andrelton Simmons and then Yovani Gallardo for John Lackey.  Otherwise, the trade remained the same.

It should also be noted that the CAFBL commissioner has agreed to submit this revised trade for review just days after it was initially rejected.  Rule 9.5 of the CAFBL constitution states that:

If a trade is overturned on merit, the same or functionally same trade may not be re-executed until at least one week after the overturned trade was accepted.

The commissioner has the discretion to determine whether a trade is the same or functionally the same so as to determine whether it falls within the purview of Rule 9.5.  As such, we defer to the CAFBL commissioner for his decision to re-submit this trade for review less than one week after the previous one was rejected on merit.

As we have discussed before, the CAFBL’s rules specifically state that the validity and equitability of trades shall primarily consider the overall integrity and competitiveness of the current season.  As such, the Court defers to the league’s guidelines for the standard of review.  This means that we will deviate somewhat slightly from the norm and focus on the immediate effect and impact of this trade rather than broaden the scope and break down the long-term benefits typically afforded in keeper league trades.  In Pursuit of the Grail vs. Screaming Psychopaths, 6 F.J. 5 (February 2014).

Nothing has changed in terms of the elite players being traded by Miggy is Back.  Both Ryan Braun and Felix Hernandez are premier fantasy players which necessitates a fair and equitable package in return for them.  The Court hereby incorporates by reference the analysis provided in Coming From Behind vs. Miggy is Back, 6 F.J. 250 (June 12, 2014) with respect to players that remain in this modified version of the trade.  As such, we must determine whether substituting Andrelton Simmons and John Lackey for Jhonny Peralta and Yovani Gallardo is substantial enough to mitigate the disparity between the trade packages.

The Court acknowledges that switching from Peralta to Simmons does minimally decrease the value of the package going to Coming From Behind.  Peralta is batting .227 with 10 home runs, 26 RBI, 26 runs scored and one stolen base.  In comparison, Simmons is batting is batting .256 with five home runs, 19 RBI, 17 runs scored and one stolen base.  The biggest differences between them are in batting average and home runs, but otherwise they are relatively comparable.

In the same vein, switching from Gallardo to Lackey also minimally increases the value of the package going to Miggy is Back.  Gallardo is 4-4 with a 3.50 ERA, 1.24 WHIP and 68 strikeouts in 84.2 innings.  In comparison, Lackey is 8-4 with a 3.24 ERA, 1.21 WHIP and 81 strikeouts in 94.1 innings.  Besides wins (which can be an arbitrary statistic that does not necessarily equate to the value or quality of a pitcher), the statistical comparison between them is also marginal.

The Court concedes that there is no collusion being alleged and the motivations of both teams fall in line with the typical dichotomy of keeper league teams heading in opposite directions in the standings.  However, the CAFBL rules specifically emphasize the fairness and integrity of trades during the current season.  Despite these teams’ attempts to modify the trade, the fact remains that the compensation being exchanged is far too disparate to conclude it is equitable for 2014.  Coming From Behind would be receiving far greater value for the rest of this season and the difference in value does not comply with the CAFBL’s rules regarding maintaining competitiveness during the current season.  Based on the foregoing, the Court rejects this amended trade between Coming From Behind and Miggy is Back.


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