Stritz-4-U vs. Kalamunda Rangers – 6 F.J. 381 (July 15, 2014) – Fantasy Baseball Trade Review (G.Stanton/J.Bautista/C.Kluber)


Stritz-4-U vs. Kalamunda Rangers


Decided July 15, 2014
Cite as 6 F.J. 381 (July 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 Giancarlo Stanton (OF-MIA, can be kept for $35.00 in 2015), J.D. Martinez (OF-DET, can be kept for $8.00 in 2015), Omar Infante (2B-KC, can be kept for $8.00 in 2015), Mike Leake (SP-CIN, can be kept for $8.00 in 2015), Jake Smolinski (3B/OF-TEX, can be kept for $8.00 in 2015), and Arismendy Alcantara (SS-CHC, can be kept for $8.00 in 2015) to the Kalamunda Rangers in exchange for Jose Bautista (OF-TOR, can be kept for $41.00 in 2015), Jason Kipnis (2B-CLE, can be kept for $32.00 in 2015), Corey Kluber (SP-CLE, can be kept for $6.00 in 2015) and Fernando Rodney (RP-SEA, can be kept for $13.00 in 2015).

Issue Presented

(1)   Should the trade between Stritz-4-U and the Kalamunda Rangers 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 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 Giancarlo Stanton, J.D. Martinez, Mike Leake, Omar Infante, Jake Smolinski and Arismendy Icantara in exchange for Jose Bautista, Jason Kipnis, Corey Kluber and Fernando Rodney looks slightly inequitable in terms of present day value.  Giancarlo Stanton and Jose Bautista 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 fact that they are on opposite sides of this trade helps balance out the inclusion of such star players.  Stanton is batting .294 with 21 home runs, 63 RBI, 61 runs, and eight stolen bases.  Bautista is batting .291 with 17 home runs, 54 RBI, 58 runs scored, and four stolen bases despite missing some time with an injury.  There is no doubt that these players cancel each other out based on this statistical comparison.

When a trade such as this is consummated involving the exchange of players at all 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 record is devoid of any information regarding where either of these teams are in the standings.  However, we can surmise that Stritz-4-U is employing a “win now” mentality by making this deal.  Despite the fact that Kipnis and Infante have relatively similar numbers, Kipnis is the better player with more value.  He has a bigger upside with his 20/20 potential, but he has dealt with a lingering injury all season and historically fades in the second half.

Stritz-4-U unquestionably improves its pitching with the acquisitions of Kluber (9-6 with a 3.00 ERA, 1.20 WHIP and 142 strikeouts) and Rodney (27 saves).  The Kalamunda Rangers conversely sustain a downgrade as Mike Leake does not offer much in terms of compensation.  However, they appear to be building for the future with the acquisitions of Smolinski and Alcantara.  Both of these rookies are currently playing in the big leagues and have had success, albeit in small samples.  Smolinski should see ample playing time the rest of the season because Texas has fallen out of playoff contention and has endured multiple injuries which have afforded opportunities for young players such as him.  Alcantara could also see an extended audition at second base for the Cubs.

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).  This star-studded trade is filled with elite players, but the compensation being exchanged is fair and equitable.  In addition, the deal also falls in line with the dichotomy of keeper league trade strategy.  Based on the foregoing, the Court approves the trade between Stritz-4-U and the Kalamunda Rangers.


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