Bill & Suzie’s Tavern vs. 2 Louns Crew – 6 F.J. 426 (July 23, 2014) – Fantasy Baseball Trade Review (Y.Molina/H.Pence/M.Ozuna)

SUPREME COURT OF FANTASY JUDGMENT

Bill & Suzie’s Tavern vs. 2 Louns Crew

ON PETITION FOR WRIT OF CERTIORARI FROM
THE INCONTINENT LEAGUE

Decided July 23, 2014
Cite as 6 F.J. 426 (July 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

Bill & Suzie’s Tavern traded Yadier Molina (C-STL, $2.10 in the second year of his existing contract with one year remaining), Marcell Ozuna (OF-MIA, $0.50 in the second year of his existing contract with one year remaining) and Adam Duvall (3B-SF, $0.50 in the minor leagues) to 2 Louns Crew in exchange for Hunter Pence (OF-SF, $2.50 in the second year of his contract with one year remaining) and Chris Heisey (OF-CIN, $1.20 in the second year of his existing contract with one year remaining).

Issue Presented

(1)   Should the trade between Bill & Suzie’s Tavern and 2 Louns Crew 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 Yadier Molina, Marcell Ozuna and Adam Duvall in exchange for Hunter Pence and Chris Heisey looks fair and equitable in terms of present day value.  None of the players in this trade are considered elite for purposes of requiring additional scrutiny merely because of how valuable they are.  See Steelers vs. Patriots, 3 F.J. 216, 220 (November 2011).   While Molina is one of the top catchers in fantasy baseball, he is currently on the disabled list and will miss the next two months after having surgery to repair a torn ligament in his thumb.

This trade epitomizes the dichotomy of keeper league trade strategy where one team in contention has a “win now” mentality by acquiring more expensive players who may not be under contract following the season, coupled with a trade partner who building for the future by selling off assets.  Knights vs. Seawolves, 5 F.J. 46, 48 (May 2013).  Bill & Suzie’s Tavern is currently in 1st and is looking to maintain their position on top of the league.  With Molina out for a couple months, he appears to be seeking a replacement bat for him.  However, they did not replace Molina (.287 with seven home runs, 30 RBI and 30 runs scored) with another catcher in this deal, so it seems as though they are choosing to essentially punt the catcher’s position.  This strategy is well within their rights in terms of roster management.

On the other hand, 2 Louns Crew is in last place and has clearly conceded the current season in an attempt to build for 2015.  With Molina on the disabled list for quite awhile, he will likely have to wait until 2015 to reap the benefits of having him.  This falls squarely in line with the strategy to play for next year when he will have one of the best catchers in fantasy baseball on his roster.  In addition, he has acquired two young players in Ozuna and Duvall who are less expensive than Hunter Pence.  Ozuna’s statistics thus far (.272 batting average with 15 home runs, 54 RBI, 46 runs scored and three stolen bases) are not too far off from those of Pence who is clearly the more consistent and established player.

Because of Molina’s injury, the package being sent to Bill & Suzie’s Tavern has more present day value despite Pence and Ozuna being generally statistically comparable.  Pence contributes in all roto categories and currently is batting .304 with 13 home runs, 38 RBI, 73 runs scored and nine stolen bases.  White it is normally acceptable for teams in keeper leagues to make trades that do not have equivalent present-day value, a deal that is so completely lopsided and goes against the best interests of the league will be rejected.  See Smittydogs vs. Moneyball, 4 F.J. 57 (May 2012) (rejecting a trade of Ryan Braun and Edwin Jackson in exchange for Randall Delgado, Dee Gordon and Bobby Abreu); Team Sabo vs. 4 Ponies, 4 F.J. 50 (May 2012) (rejecting a trade of Joey Votto and Tyler Clippard in exchange for Drew Stubbs, Francisco Rodriguez and Starling Marte).  That is not the case here.

This trade falls square within the keeper league trade strategy dichotomy.  There is sufficient value being exchanged for each other.  The motivations of both teams are obvious and the deal satisfies the needs of both parties.  Based on the foregoing, the Court approves the trade between Bill & Suzie’s Tavern and 2 Louns Crew.

IT IS SO ORDERED.

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