Miami Exxpos vs. Bada Bing Boys – 6 F.J. 451 (August 1, 2014) – Fantasy Baseball Trade Rejected (R.Cano/Z.Greinke/D.Keuchel)

SUPREME COURT OF FANTASY JUDGMENT

Miami Exxpos vs. Bada Bing Boys

ON PETITION FOR WRIT OF CERTIORARI FROM
THE JABRONI LEAGUE

Decided August 1, 2014
Cite as 6 F.J. 451 (August 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

The Miami Exxpos traded Robinson Cano (2B-SEA, can be kept for $37.00 in 2015) and Zack Greinke (SP-LAD, can be kept for $32.00 in 2015) to the Bada Bing Boys in exchange for Lance Lynn (SP-STL, can be kept for $9.00 in 2015), Dallas Keuchel (SP-HOU, can be kept for $8.00 in 2015) and Hisashi Iwakuma (SP-SEA, can be kept for $13.00 in 2015).

Issue Presented

(1)   Should the trade between the Miami Exxpos and the Bada Bing Boys 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 Robinson Cano and Zack Greinke in exchange for Lance Lynn, Dallas Keuchel and Hisashi Iwakuma looks completely inequitable based on present day value.  Both Cano and Greinke 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 being traded together in exchange for a package of players that does not include an elite player tends to infer that the deal is lopsided.

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).

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 that the Bada Bing Boys are pursuing a league championship this year and to win right now by acquiring the expensive contracts of Cano and Greinke.  In contrast, the Miami Exxpos appear to be conceding the current season by selling off expensive assets in exchange for less expensive players.

Cano is unquestionably the best second baseman in both real and fantasy baseball.  While his power numbers have decreased since moving to Seattle, he has seen an uptick in his batting average and could be in line for a batting title.  His .328 average with seven home runs, 59 RBI, 51 runs scored and eight stolen bases still make him the most valuable second baseman in the league.

If not for his teammate Clayton Kershaw, Zack Greinke could be in line for a Cy Young award this year compiling a 12-6 record with a 2.64 ERA, 1.15 WHIP and 153 strikeouts in 139.1 innings.  He has been dominant for most of the season and has great long-term value as well.

The package being sent to the Miami Exxpos is comprised of three decent pitchers in Lynn, Keuchel and Iwakuma.  None of them provide elite production in any category, nor are any of them viable keeper candidates for 2015.  The JL permits GM’s to keep up to six players per season.  Even without knowing the composition of the Miami Exxpos roster, we can conclude that Lynn, Keuchel and Iwakuma are not likely to be kept.

Despite the fact that the JL is a keeper league and both teams’ motivations are in good faith with respect to the dichotomy of keeper league trade strategy, the disparity between the packages is far too great to pass muster.  Lopsided trades throw off the competitive balance of the league and create a slippery slope for future trades.  The Court has no issues with the idea of trading superstar players so long as the package in return is equitable and makes sense given the needs of both teams.  See 4 Ponies vs. Beaver Hunters, 3 F.J. 26, 29 (June 2011).  The Miami Exxpos are clearly dumping Cano and Greinke, but the compensation they are acquiring makes no sense based on both present day and long-term value.

We also understand that the Miami Exxpos would net $39.00 in salary cap relief by making this deal.  While obtaining salary cap flexibility in a keeper is league is one of the many objectives teams have for making trades to rebuild for the future, its benefits can be trumped by the inequitability of the current players being traded away.  Beaver Hunters vs. 4 Ponies, 4 F.J. 129, 131 (July 2012).  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.  See Los Pollos Hermanos vs. Little Stumps, 3 F.J. 192, 195 (October 2011); see also Speedboys vs. Kramerdogs, 5 F.J. 109 (July 2013) (rejecting a trade of Paul Goldschmidt, Adam Wainwright and Rafael Soriano in exchange for Bryce Harper, A.J. Burnett Trevor Rosenthal, and Archie Bradley).  That is what appears to be the case here.  Based on the foregoing, the Court rejects the trade between the Miami Exxpos and the Bada Bing Boys.

IT IS SO ORDERED.

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