Stritz-4-U vs. Fire & Ice – 6 F.J. 271 (June 20, 2014) – Fantasy Baseball Trade Review (J.Segura/F.Rodriguez/G.Perkins)

SUPREME COURT OF FANTASY JUDGMENT

Stritz-4-U vs. Fire & Ice

ON PETITION FOR WRIT OF CERTIORARI FROM
THE JABRONI LEAGUE

Decided June 20, 2014
Cite as 6 F.J. 271 (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

Stritz-4-U traded Alexei Ramirez (SS-CHW, can be kept for $6.00 in 2015), David Murphy (OF-CLE, can be kept for $8.00 in 2015), Tyler Flowers (C-CHW, can be kept for $8.00 in 2015) and Francisco Rodriguez (RP-MIL, can be kept for $8.00 in 2015) to Fire & Ice in exchange for Derek Norris (C-OAK, can be kept for $8.00 in 2015), Jean Segura (SS-MIL, cannot be kept), Rajai Davis (OF-DET, cannot be kept) and Glen Perkins (RP-MIN, can be kept for $17.00 in 2015).

Issue Presented

(1)   Should the trade between the Stritz-4-U and Fire & Ice 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 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 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 Alexei Ramirez, David Murphy, Tyler Flowers and Francisco Rodriguez in exchange for Derek Norris, Jean Segura, Rajai Davis and Glen Perkins looks fair and equitable.  None of the players in this deal 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).

When a trade such as this is consummated involving the exchange of players at the same position, it can reasonably be concluded that neither GM has any specific positional need to fill and is rather looking to upgrade or improve at those positions.  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).  We can surmise Stritz-4-U is looking to contend for a league championship and win right now by acquiring the expiring contracts of Jean Segura and Rajai Davis.  Neither can be retained in 2015 so the benefits afforded Stritz-4-U are solely for the purposes of this season.

In contrast, Fire & Ice was going to lose both Segura and Davis at the end of the season for nothing.  Rather than see Segura and Davis re-enter the draft without anything to show for them, Fire & Ice was able to obtain some form of compensation in exchange for them.

This deal represents a straight exchange of players at the same position.  Despite the contractual status of Segura and Davis, all players involved in this trade have comparable value.  The combination of Segura and Davis indicates that Stritz-4-U is in need of improvement in stolen bases which serves his aforementioned “win now” mentality.  In exchange, Fire & Ice obtains Alexei Ramirez who provides solid production in batting average, runs scored and a handful of stolen bases as well.  He can be retained at a minimal cost for Fire & Ice as they build towards 2015.  The two closers being swapped are also equitable.  Francisco Rodriguez is having a career renaissance with the Brewers with an incredible 23 saves to date.  Glen Perkins has been one of the most consistent relievers in baseball since emerging as the Twins closer in 2012.  Finally, the exchange of Derek Norris (.306 with eight home runs and 34 RBI) for Tyler Flowers (.243 with five home runs and 20 RBI) represents fair value even though Norris is statistically better.

Even without knowing their rosters or the current standings, this 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).  The compensation being exchanged is fair and equitable, and the deal itself satisfies their respective needs.  Based on the foregoing, the Court approves the trade between Stritz-4-U and Fire & Ice.

IT IS SO ORDERED.

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