Outlaws vs. Darkhorse – 6 F.J. 628 (November 17, 2014) – Fantasy Football Trade Review (A.Rodgers/C.Newton/J.Clowney)


Outlaws vs. Darkhorse


Decided November 17, 2014
Cite as 6 F.J. 628 (November 2014)

Factual Background

A fantasy football league called the Couch Potato Football League (hereinafter referred to as “CPFL”) is a 16-team standard keeper league created in 1989 and hosted on MyFantasyLeague.com.  Every year, each team may select six (6) players to keep which includes three offensive players and three defensive players.

The CPFL employs the following scoring system: Offense (1 point per 20 yards passing, 1 point per 10 yards rushing and receiving, 3 points per passing touchdown, 4 points per rushing or receiving touchdown, and -1 point per interception thrown); Defense (0.5 points per tackle, assist or batted ball, 1.5 points per ½ sack, 3 points per sack or interception, and 3 points per defensive touchdown); and Kicking (-1 point per missed field goal, 3 points per field goal made under 49 yards, and 4 points per field goal made 50 yards or more).

The CPFL has the following rules regarding trades:

8.     TRADING

         A. If you trade a draft pick, you must receive the same number of draft picks back.

         B. All trades will be sent to Fantasy Judgment for review.

         C. Trades will take place from the start of the season (owners meeting) until after the 8th week of the season.

         D. No trades will be allowed after the keepers are announced until after the draft.

               *          *          *          *          *

         F. Players traded after midnight on Friday during the season will not go through until the following Tuesday.

The CPFL commissioner has submitted a trade to the Court for review.

Procedural History

The Outlaws traded Cam Newton (QB-CAR), Derek Anderson (QB-CAR), Jadeveon Clowney (LB-HOU) and its 1st, 2nd, 3rd and 5th round draft picks in 2015 to Darkhorse in exchange for Aaron Rodgers (QB-GB), Nick Perry (LB-GB), Mychal Kendricks (LB-PHI) and its 8th, 14th, 23rd and 24th round draft picks.

Issue Presented

(1) Should the trade between the Outlaws and Darkhorse 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.

Typically the only circumstances where we will reject a trade are: 1) if the deal is made in violation of league rules; 2) if the deal is made through collusion; 3) the deal is so grossly lopsided that is has a detrimental effect on the whole league; and 4) if the deal makes absolutely no sense and/or fails to improve at least one of the team’s rosters in any capacity.  Grand Theft Votto vs. That Wimpy Deer, 6 F.J. 39, 42 (April 2014).  Given the concerns over this trade, we will only look at scenarios 3 and 4.

In a vacuum, the trade of Cam Newton, Derek Anderson, Jadeveon Clowney and four early round draft pick in exchange for Aaron Rodgers, Nick Perry, Mychal Kendricks and four mid-to-late round draft pick looks fair and equitable in terms of both present day and future value.  Rodgers is one of the top three quarterbacks in the league and is certainly considered elite which would require additional scrutiny because of how inherently valuable he is.  See Steelers vs. Patriots, 3 F.J. 216, 220 (November 2011).

This trade includes a swap of quarterbacks and linebackers along with draft picks.  Draft picks in subsequent seasons are assets commonly bartered in keeper leagues.  See Bald Eagles vs. Weasel D, 3 F.J. 205, 208 (November 2011).  When a trade such as this is consummated involving the exchange of players at the same positions, it can reasonably be concluded that both GM’s do not have any specific positional needs to address.  Rather, they are seeking specific improvement in a particular category or have other keeper league strategies in mind.  See Mudhen Wannabe’s vs. Screaming Psychopaths, 6 F.J. 399 (July 2014).

It seems evident that Darkhorse is continuing its rebuilding process by trading away an elite quarterback like Rodgers to stockpile draft picks for 2015.  Acquiring a 1st, 2nd, 3rd and 5th round pick in this deal sets them up nicely to build through the draft next season while also obtaining a respectable quarterback in Newton.  Despite Carolina’s awful offense, Newton can still be a dynamic quarterback with the combination of his strong passing arm and running capabilities.

The Outlaws unquestionably improve at the quarterback position by acquiring Rodgers who has been outstanding again this season.  Putting him in their lineup improves the Outlaws’ chances of earning a postseason berth and making a run at the CPFL championship.  They are well within their rights to sacrifice future assets in exchange for present-day benefits in this keeper league.

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).  Here, the trade makes sense from both teams’ perspectives and serves their respective needs.  The compensation being exchanged is fair and equitable in terms of both present and future value.  We see no reason why this trade should not go through.  Based on the foregoing, the Court approves the subject trade between the Outlaws and Darkhorse.


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