Grand Theft Votto vs. That Wimpy Deer – 6 F.J. 39 (April 4, 2014) – Fantasy Baseball Trade Dispute (J.Upton/B/McCann)


Grand Theft Votto vs. That Wimpy Deer


Decided April 4, 2014
Cite as 6 F.J. 39 (April 2014)

Factual Background

A rotisserie fantasy baseball league called the Bush Leagues (hereinafter referred to as “BL” was established in 2014 and is hosted on Yahoo.  The BL is a 14-team mixed AL/NL keeper league utilizing an auction-style draft with a budget of $260.00 for 25 players.  Teams are permitted to maintain up to eight (8) players during each off-season with players’ salaries increased by $3.00 each year they are kept.

The BL uses a 6×6 format for its scoring categories to determine the standings and prize money.  For offensive players, the six categories are: (1) batting average; (2) homeruns; (3) runs batted in; (4) runs scored; (5) stolen bases; and (6) OPS.  For pitchers, the six categories are: (1) wins; (2) earned run average; (3) WHIP (walks+hits/innings pitched); (4) strikeouts; (5) quality starts; and (6) saves.

After a trade between two GM’s is made, it sits in the league’s inbox for three days.  Other GM’s can send the trade for arbitration if they so choose.  If no one sends the trade for arbitration after three days, then the trade is officially approved.

A league member has submitted a trade to the Court for review to determine whether it should be approved or rejected.

Procedural History

Grand Theft Votto traded Brian McCann (C-NYY, $8.00 salary in 2014) and Dexter Fowler (OF-HOU, $3.00 salary in 2014) to That Wimpy Deer in exchange for Justin Upton (OF-ATL, $21.00 salary in 2014) and Brandon Belt (1B-SF, $5.00 salary in 2014).

Issue Presented

(1)   Should the trade between Grand Theft Votto and That Wimpy Deer 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 BL 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 Brian McCann and Dexter Fowler in exchange for Justin Upton and Brandon Belt looks fair and equitable.  None of the players involved in this trade are considered elite for purposes of requiring additional scrutiny merely because of their inherent value or projected 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 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).

That Wimpy Dear was approached by Grand Theft Votto who was interested in dealing for Justin Upton.  While Upton is a very talented player with potential to contribute in batting average, power and stolen bases, he has yet to live up to his potential as demonstrated by his inconsistent inaugural season in Atlanta last year.  After an incredible April where he hit .298 with 12 home runs, 19 RBI’s, 22 runs scored, and a 1.136 OPS, Upton wholly disappointed fantasy owners with a disappointing remainder of the season that never came close to matching his first month’s outburst. The Wimpy Dear felt they may have overpaid for Upton at $21.00 and was interested in making a deal out of fear of him failing to reach such high expectations.

When looking at Grand Theft Votto’s roster for desirable acquisitions, he immediately targeted Brian McCann.  This makes perfect sense given Dioner Navarro is his only catcher.  McCann is expected to thrive with the Yankees, especially given the fact he is hitting in a deep and talented lineup, has the luxury of being a DH on occasion, and can take advantage of the short right field fence at Yankee Stadium.  Despite batting injuries over the past couple years, McCann is healthy once again and is projected to be one of the most productive catchers in fantasy baseball.

While Upton and McCann were the opposing centerpieces of the trade, the secondary players also have great value to both teams.  The GM who challenged this trade made arguments based on Fowler’s disparate home and away splits when he played home games at Coors Field with the Rockies.  While his numbers generally were better at Coors Field, that does not undermine the value and talent he does possess.  Injuries have played a significant role in halting his development, but a fresh start in Houston could be all that he needs.  By default, he is the most established player in the Astros’ lineup and will have an opportunity to be the star of that team.

Minute Maid Park is a hitter-friendly stadium[1], especially for a player like Fowler who can take advantage of the spacious outfield and utilize his speed with doubles and triples.[2]  Remember, OPS is one of the categories in the BL so those extra base hits will come in handy for That Wimpy Deer.  In addition, Fowler’s stolen bases are much needed for That Wimpy Deer who lost Jose Reyes to the disabled list on Opening Day.

In terms of Brandon Belt, he is another player who has taken longer than expected to develop.  The Giants have remained patient with Belt despite his struggles over the past few seasons.  He began showing signs of life in 2013 and has been projected to have a breakout season this year by batting higher in the order and also getting stronger as he ages.[3]  Grand Theft Votto can simply move Mark Trumbo to his outfield and plug Belt in at first base and get similar production to what Fowler brings to the table, minus some stolen bases in all likelihood.

Looking at the competing needs of both teams, this trade makes perfect sense.  None of the players are so far superior to the others that it creates the appearance of inequity.  The biggest disparity between the two packages is the combined salaries of the players.  Grand Theft Votto is taking on an extra $15.00 in contracts which is just under 6% of the teams’ auction draft budgets.  While that is not a trivial amount, it by no means is significant enough to imply any sort of imbalance or inequity.

Members of the BL have been given the right to challenge trades and call for arbitration, so the appellant is certainly well within his rights to make this appeal.  However, the evaluation provided in disputing the deal does not equate to a level of imbalance that warrants overturning or rejecting a proposed trade.  Besides trades that are made in violation of league rules, through collusive efforts, or are so grossly lopsided that they have a detrimental effect on the whole league, the only other circumstance where the Court would reject a trade is if the deal made absolutely no sense or improved one of the teams in any capacity.  This deal clearly makes 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).  Based on the foregoing, the Court approves the trade between Grand Theft Votto and That Wimpy Deer.


[1] See

[2] See

[3] See

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