Fantasy Judgment decision – October 26, 2010 (fantasy football trade dispute)
THE SUPREME COURT OF FANTASY JUDGMENT
Silveramo v. Nation
ON PETITION FOR WRIT OF CERTIORARI FROM
AN ANONYMOUS FANTASY FOOTBALL LEAGUE
Decided October 26, 2010
Cite as 2 F.J. 38 (October 2010)
Factual Background
A complaint has been filed by a member of an anonymous fantasy football league (hereinafter referred to as “FFL”) challenging a trade made between two other teams. It is unknown what website the FFL is hosted on. The complaint is also devoid of additional information regarding the structure of the league, including whether it is a keeper league or how many teams there are. It is also unknown what the FFL’s rules are regarding trades and the approval process. There is no reference to a league Constitution and no rules or guidelines were provided in the complaint.
Starting lineups in the FFL consist of the following: QB (1), RB (2), WR (2), TE (1), FLEX (1 – RB/WR/TE), K (1), and DEF/ST (1). The scoring system for the FFL is as follows:
Passing
Touchdown = 4 points
Every 40 Yards = 1 point
Bonus at 300 Yards = 3 points
Rushing/Receiving
Touchdown = 6 points
Every 20 Yards = 1 point
Bonus at 100 Yards = 3 points
Touchdown Bonuses
Passing, Rushing, Receiving TD of 40-59 Yards = 2 points
Passing, Rushing, Receiving TD of 60-79 Yards = 4 points
Passing, Rushing, Receiving TD of 80+ Yards = 6 points
Receptions
Each reception = .5 points beginning with the 4th reception.
0-3 catches = 0 points
4 catches = 2 points
5 catches = 2.5 points
The plaintiff has challenged a trade made between Silveramo, the 1st place team in his division (5-2), and Nation, the 3rd place team in his respective division (4-3). Silveramo has offered to trade LeSean McCoy (RB-PHI), Ben Roethlisberger (QB-PIT), and Brandon Lloyd (WR-DEN) to Nation in exchange for Chris Johnson (RB-TEN), Kevin Kolb (QB-PHI), and Jeremy Maclin (WR-PHI).
Procedural History
The complaining party, on behalf of the rest of the FFL, is challenging the validity of this trade. Specifically, they question how this trades improves Nation who gave up Chris Johnson, arguably the best running back in the NFL (and the likely #1 draft pick in most fantasy football leagues this season), in exchange for LeSean McCoy who is on a bye this coming week (Week 8). Additionally, the complaining party argues that Nation does not need Brandon Lloyd because, according to the complaint, “he has great receivers.” The receivers on Nation’s roster at the time of this proposed trade include Anquan Boldin (WR-BAL), DeSean Jackson (WR-PHI), and Roy Williams (WR-DAL). Finally, the complaining party argues that Ben Roethlisberger constitutes an upgrade at quarterback over Donovan McNabb and Matt Ryan. However, he questions the significance of this upgrade when only one quarterback is in the starting lineup every week.
It was conceded in the complaint that there is no suspicion of collusion or cheating between Silveramo and Nation. The nature of the complaint is whether the trade was intelligently entered into.
Issue Presented
(1) Should the trade between Silveramo and Nation be approved?
Decision
The Supreme Court of Fantasy Judgment typically favors individual fantasy sports participants and teams’ ability to make moves, transactions, and trades. See Smittydogs v. Moneyball, 1 F.J. 32, 33 (June 2010). The standard of review has been that people pay money to purchase a team in a league, draft their team, and manage it accordingly. Whether success is bred from that individual’s decision-making is purely left to some skill, luck, dedication, and savviness. The Court also acknowledges that the analysis for evaluating trades is much different in a keeper league than a non-keeper league. A trade that may look uneven or lopsided on its face may receive a different opinion when it is involved in a keeper league. The reasons for this are obvious, but must be restated. In a keeper league, teams that are having unsuccessful seasons are more likely to continue to pay attention and make moves that will set themselves up for better success in the following season. They can do this by acquiring young talent that is not under contract within the league, or by dumping salary (assuming it is an auction league) and allowing greater financial flexibility to sign key players in the next season’s draft. In non-keeper leagues, there is no rationale for thinking ahead, nor is there any need to stockpile young, inexpensive talent. However, it is not known whether the FFL is a keeper league or not. As a result, the standard of review will assume that it is not a keeper league and the Court will analyze the players involved in the trade based on their current and past statistics and performance as opposed to projections for future NFL seasons.
Another factor that the Court must always consider is whether there is any collusion or under-the-table dealings going on between teams. As stated above, the complaining party has admitted that there are no allegations of collusion or cheating. Therefore, the Court will forego an analysis into this scenario.
At first glance, the trade of LeSean McCoy, Ben Roethlisberger and Brandon Lloyd in exchange for Chris Johnson, Kevin Kolb and Jeremy Maclin looks fair and even. The eye-catcher in this deal is clearly Chris Johnson, arguably the best running back in the NFL in both reality and in fantasy. Any trade involving the #1 overall pick and most dominant fantasy player is going to create controversy and invite skepticism. However, when the numbers and statistics are broken down, Johnson and McCoy are practically even.
Rush Yds Receptions Rec. Yards Touchdowns
Chris Johnson 662 17 66 7
LeSean McCoy 477 38 293 5
Johnson’s success has made him a target for NFL defenses, and it is obvious that teams are focusing on shutting Johnson down to prevent his prototypical breakout run. This means that putting up similar statistics to what he did in 2009 will almost be impossible. On the other hand, LeSean McCoy has become the focus of the Philadelphia Eagles offense in both the passing and running games. Cumulatively, McCoy currently has more total yards (770) than Johnson (728), has double the number of receptions, and is almost identical in scoring touchdowns. Consequently, there is not much of a drop-off at all in trading Johnson for McCoy. The argument that this makes no sense because McCoy has a bye week this weekend is speculative. While it is true that the Eagles have their bye week, analyzing the rationale as to why this trade was made and when it was made is a process that the Court refuses to do.
To help make up the perceived difference in trading Johnson, Nation was able to acquire Ben Roethlisberger and Brandon Lloyd. Roethlisberger is certainly an upgrade over Kolb as Big Ben has almost eclipsed Kolb’s statistics despite playing in three less games. Big Ben is also an upgrade over the other two quarterbacks that he now shares a fantasy roster with – Donovan McNabb and Matt Ryan. The question over the sensibility of this trade because teams only start one quarterback per week is unfounded. Any fantasy football participant has the right (so long as the roster and rules allow it) to accumulate as many backups for position depth, injuries, and trade bait. Nation’s acquisition of Brandon Lloyd was also needed because DeSean Jackson is questionable for the near future due to the severe concussion he sustained during Week 6. Nation clearly needed a wide receiver, and since the Eagles are off this week, he included Jeremy Maclin in the deal for Lloyd, who will immediately become a starter. His needs were clearly served and he got fair market value for Chris Johnson.
The exchange of fair value is also demonstrated by Silveramo’s acquisitions from his perspective. He acquired Kolb when he already has Michael Vick. The Eagles have shown that they can score points no matter who is playing quarterback. Having both the starter and backup ensures that Silveramo will have an effective starting quarterback every week. Acquiring Jeremy Maclin gives Silveramo a good QB-WR combination, which is just as effective no matter who the quarterback is in Philadelphia.
More importantly, the complaining party has admitted that he is not challenging this trade based on collusion, cheating or any other reason besides it being dumb. The scope of the Court’s authority is to govern and advise when there is a dispute as to the validity of trades, rulings, decisions or other issues that arise within fantasy sports leagues. Making a judgment on whether an individual did something stupid is not what the Court does. As stated earlier, teams should be given the opportunity to make deals and try and improve their teams, even if that means they will make unintelligent decisions from time to time.
Based on the fact that the players involved in the trade are fair and equal coupled with the admission that the complaining party seeks Court intervention due to the trade allegedly being “stupid,” the Court hereby decides that the subject trade is fair and should be allowed. The subjective reasons why teams make trades should not be speculated about unless there is tangible evidence of collusion and the nature of the complaint provides sufficient information and background to corroborate such a story.
IT IS SO ORDERED.
