Evil Empire vs. Rocafellas – 6 F.J. 507 (August 14, 2014) – Fantasy Baseball Trade Review (H.Ramirez/C.Santana/F.Freeman)


Evil Empire vs. Rocafellas


Decided August 14, 2014
Cite as 6 F.J. 507 (August 2014)

Factual Background

A head-to-head points-based fantasy baseball league called the Pelham Bay Keeper League (hereinafter referred to as “PBKL” was established in 2002 and is hosted on CBS. The PBKL is a 12-team mixed AL/NL keeper league where teams are required to retain four (4) players. At least one keeper must have had a salary of $2.00 during the previous season and the other three keepers can have any salary. Any player not selected as a keeper will be eligible for the next season’s draft. Keepers must be announced seven days prior to the draft date. Once keepers are announced, owners may only trade one of their four keepers. Owners may not trade players that they have not elected as one of their keepers. Prior to keepers being announced, owners may trade any player from last season’s roster with the understanding that the players involved in the trade must be kept.

The salary cap for each team is $310 which includes reserves and DL players. The salary cap will increase to $325 on July 1st. The salary for keepers will be increased as follows:

1st year: $5.00 added on to the original salary he was on your team for.
2nd year: $10.00 added on to the player’s salary after the 1st year.
3rd year: $15.00 added on to the player’s salary after the 2nd year.
4th year: $20.00 added on to the player’s salary after the 3rd year.

The PBKL’s rules regarding trades are as follows:


10.1. Teams are allowed to make trades until 11:59 PM on August 31.

10.2. If a pitcher is involved in a trade, that pitcher must be kept for 3 starts or 14 lineups. A violation of this rule will result in an illegal move.

10.3. If a trade causes a team to have an illegal roster that team must correct it via waiver wire/free agency prior to lineups locking or else they will be subject to an illegal lineup.

10.4. Any team that acquires a player in a trade made prior to draft day is forced to keep the player acquired in the trade, unless a serious injury occurs.

10.5. There is no limit to the number of trades a team may make during the season.

10.6. Future year’s draft picks may be traded on July 1st and beyond, subject to approval. A maximum of 2 future draft picks may be traded during the regular season. Draft picks traded for keepers in the offseason are allowed. (a $50 deposit (per pick) is required by any team trading away a future pick).

10.7. The only “condition” you can include in a trade is a conditional draft pick regarding where they finish in the standings. You cannot add a condition that will prevent an owner from keeping a player acquired in a trade.

10.8. The fairness of all trades will be decided by a 3rd party website service.

The commissioner has submitted a trade to the Court for review to determine whether it should be approved or rejected.

Procedural History

The Evil Empire traded Hanley Ramirez (SS-LAD, $20.00 salary in 2014 which increases to $30.00 if kept in 2015), Gregory Polanco (OF-PIT, $2.00 salary in 2014), James Loney (1B-TB, $12.00 salary in 2014) and Bud Norris (SP-BAL, $5.00 salary in 2014) to the Rocafellas in exchange for Carlos Santana (C/3B-CLE, $15.00 salary in 2014), Freddie Freeman (1B-ATL, $21.00 salary in 2014 which increases to $31.00 if kept in 2015), and Bartolo Colon (SP-NYM, $21.00 salary in 2014).

Issue Presented

(1)   Should the trade between the Evil Empire and the Rocafellas 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 PBKL 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 Hanley Ramirez, Gregory Polanco, James Loney and Bud Norris in exchange for Carlos Santana, Freddie Freeman and Barolo Colon looks slightly inequitable. 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). However, there are several star players on both sides of the deal.

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 are free to prioritize the areas on their rosters that they want to pursue improvement 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 Evil Empire is currently in 7th place and the Rocafellas are currently in 11th place, so it appears both teams are entering into this deal with the future in mind. Hanley Ramirez is the most valuable player in this trade, but he is currently on the disabled list with an oblique injury and there is no timetable for his return. Despite dealing with a variety of injuries this year, Ramirez is still batting .276 with 12 home runs, 58 RBI, 50 runs scored and 12 stolen bases. When healthy, Ramirez can provide near elite production in all five roto categories. But understandably as he gets older and is now hitting in the middle of the Dodgers lineup, his stolen base totals have generally decreased which is a trend that will likely continue in the future.

Along with Ramirez, the Rocafellas also acquired Gregory Polanco, James Loney and Bud Norris. Polanco is one of the biggest prospects in baseball and has been streaky during his first 56 games with the Pirates. Overall he is batting .264 with six home runs, 28 RBI, 39 runs scored and 11 stolen bases. This small sample is an indicator that he can be a solid contributor in all five roto categories as well. If he is kept, salary would only be $7.00 in 2015.

James Loney has never been a power hitter, but he has consistently put up respectable numbers in terms of batting average and RBI. As the Rays’ everyday first baseman, Loney is batting .285 with five home runs, 53 RBI, 48 runs scored and four stolen bases. He is best suited as a corner infield option on most fantasy teams. Finally, Bud Norris is 10-7 with a 3.75 ERA, 1.25 WHIP, and 91 strikeouts in 120 innings. His win total is solid and he has a serviceable ERA, but other than that he is a back of the rotation option for many fantasy GM’s.

In exchange for that package of players, the Evil Empire has acquired Carlos Santana, Freddie Freeman and Bartolo Colon. Santana has one of the most unique collections of position eligibility this season as he qualifies at catcher, first base and third base. Despite getting off to a horrendous start to the season, he has rebounded and raised his batting average to .226 to go along with 20 home runs, 56 RBI, 51 runs scored and three stolen bases. His positional flexibility and power output helps offset his terrible batting average.

Freddie Freeman was regarded as an emerging fantasy star heading into 2014 after signing a lengthy contract extension with the Braves. While his production hasn’t reached elite levels yet, he is one of the most consistent and dependable fantasy players in the league with a batting average of .290 with 16 home runs, 64 RBI, and 73 runs scored. His salary would increase to $31.00 if he is kept in 2015.

Finally, Bartolo Colon has defied Father Time by amassing an 11-10 record with a 3.84 ERA, 1.15 WHIP and 125 strikeouts. These are very solid numbers for a 41-year old pitcher on a bad team. He marks a clear upgrade over Norris despite the win totals being relatively equal.

This trade contains a mixture of prospects, present-day stars, and marginal pitchers with not a lot of future value. Both teams receive upgrades and downgrades at certain positions which is demonstrative of a GM’s personal strategy in managing a team and building a roster. The value being exchanged for each other is fair and equitable. Both sides fulfill their respective needs and have provided sufficient compensation. Based on the foregoing, the Court approves the trade between the Evil Empire and the Rocafellas.



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