New Fantasy Judgment decision - Smittydogs vs. Stud Muffins (fantasy baseball trade dispute)

SUPREME COURT OF FANTASY JUDGMENT

Smittydogs v. Stud Muffins

ON PETITION FOR WRIT OF CERTIORARI FROM

THE INCONTINENT LEAGUE

Decided May 4, 2011

Cite as 3 F.J. 16 (May 2011)

Factual Background

A rotisserie fantasy baseball league (hereinafter referred to as “Roto league” or “The Incontinent League”) utilizing an auction-style draft and transaction platform seeks an evaluation of a trade made between two teams within the Roto league.  This is an NL-only keeper league where each team is permitted to maintain up to ten (10) players during each off-season with each individual player allowed to be kept for a maximum of three (3) years.  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 $36.00 in-season salary cap that is applicable for all teams.   

As with many rotisserie leagues, the subject Roto 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.

Procedural History

The Smittydogs have made a trade with the Stud Muffins.  The Smittydogs traded Kerry Wood (RP-CHC) to the Stud Muffins in exchange for Mitchell Boggs (RP-STL). 

Issue Presented

(1)   Should the trade between the Smittydogs and the Stud Muffins be upheld and approved?

Decision

The Supreme Court of Fantasy Judgment typically favors individual fantasy sports participants and teams’ ability to make moves, transactions, and trades.  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.

Another factor that the Court must always consider is whether there is any collusion or under-the-table dealings going on between teams.  The Court has not been presented with any evidence of such malfeasance, so assumptions will be made that this is not an issue. 

At first glance, the trade of Kerry Wood in exchange for Mitchell Boggs looks fair and even.  This trade involves two relief pitchers who are not likely going to contribute much in terms of saves.  Rather, they could be effective for ERA and WHIP assuming they are both effective in a set-up role.  However, Boggs has been in contention for the Cardinals’ closer job after Ryan Franklin was removed.  Boggs had some initial success, but after a blown save just days after being named the likely closer, Cardinals’ manager Tony LaRussa has stated it will be a closer by committee situation with others such as Fernando Salas, Eduardo Sanchez and Jason Motte.  This decreases Boggs’ value if he will not get opportunities for saves.  On the other hand, Wood is the established eighth inning reliever for the Cubs setting up Carlos Marmol.  Wood will only have save opportunities if Marmol is injured, unavailable, or in need of rest. 

When analyzing the fairness and equity of a trade, the Court will consider each team’s individual needs to assess whether the trade subjectively made sense from each team’s perspective.  See Cajon Crawdads vs. Carson City Cocks, 1 F.J. 41, 42 (June 2010) (upholding a trade for Jason Bay because of the Carson City Cocks’ desperate need for a starting outfielder due to the demotion of Cameron Maybin).  Here, both teams have swapped players at the same position with relatively similar production.  There is nothing out of the ordinary to indicate either team has any ulterior motives behind the trade to question its sincerity.

In terms of keeper league status and salary cap value, this trade is almost equivocal.  Both players involved are in their first year under contract with their respective teams.  Wood is worth $0.30 while Boggs is worth $1.00.  The Stud Muffins, currently in third place, will gain $0.70 in salary cap space which is debatably not significant enough to factor into the evaluation given the equality of the players involved.  See Smittydogs v. Stud Muffins, 3 F.J. 10, 11 (April 2011) (holding that a $0.10 differential amongst the players salaries was not enough to factor into the Court’s evaluation).

As referenced in Smittydogs v. Moneyball, 1 F.J. 32, 34 (June 2010), the dichotomy between the Smittydogs and the Stud Muffins’ motivations is precisely why the Court must look at trades in keeper leagues differently than non-keeper leagues.  However, had this trade been made in a non-keeper league, the Court would still likely approve it. 

Based on the foregoing reasons, the Court hereby decides that the subject trade is fair, equal, and free of collusion.  The trade should be approved as it comports with the best interests of the league.

IT IS SO ORDERED.