New Fantasy Judgment decision - fantasy baseball trade (Carlos Pena/Geovany Soto)

SUPREME COURT OF FANTASY JUDGMENT

Carson City Cocks v. Moneyball

ON PETITION FOR WRIT OF CERTIORARI FROM THE INCONTINENT LEAGUE

Decided June 27, 2011

Cite as 3 F.J. 41 (June 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 Carson City Cocks have made a trade with Moneyball.  The Carson City Cocks traded Geovany Soto (C-CHC) to Moneyball in exchange for Carlos Pena (1B-CHC). 

Issue Presented

(1)   Should the trade between the Carson City Cocks and Moneyball 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 Geovany Soto in exchange for Carlos Pena looks fair and even.  Both players have had success in the past and have fallen on hard times over the last couple seasons.  Soto had emerged as a top fantasy option at the vacuous catcher’s position only a few years ago.  However, injuries and lack of production have relegated him to merely a second or third tier option in terms of fantasy value.  However, in a roto format, he still does possess the potential to contribute in power categories.  Carlos Pena is coming off of one of the worst seasons an everyday player can have when he failed to hit .200 during the 2010 season.  He still produces 25+ homeruns and will drive in 80-90 runs, but he is a death wish for the batting average category.  That being said, his value as a first baseman is commensurate with Soto’s value as a catcher.  They both play every day for the Chicago Cubs and have the ability to capitalize on the friendly confines of Wrigley Field during the summer months.  Neither player will hit for a high batting average, score a lot of runs, or steal many (if any) bases.  Their value lies in the homerun and RBI categories. 

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).  This trade involves one catcher and one first baseman.  Prior to the trade, the Carson City Cocks lost Albert Pujols (1B-STL) to injury for four to six weeks due to suffering a fractured wrist.  Clearly this left a void at first base or corner infielder, so it is obvious why the Carson City Cocks sought to acquire Pena.  Trading Soto does not leave them without viable catching options as they also have Jonathan Lucroy (C-MIL) and Josh Thole (C-NYM).  Conversely, Moneyball had depth at first base with Lance Berkman (1B/OF-STL), Freddie Freeman (1B-ATL) and Ty Wigginton (1B/2B/3B-COL).  This depth made Pena expendable.  Moneyball’s catchers were Miguel Montero (C-ARZ) and Eli Whiteside (C-SF), so acquiring Soto made sense as an upgrade for his second catcher.  The combination of Montero and Soto has the potential to be one of the most productive duos at that position.  Based on the foregoing analysis, the needs of each team were clearly delineated and equally met with this trade.

In terms of keeper league status and salary cap value, this trade is almost equivocal.  Both Soto and Pena are in their first year under contract with their respective teams.  Soto is worth $1.20 while Pena is worth $2.00.  Moneyball, currently in sixth place, will gain $0.80 in salary cap space which is 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 Carson City Cocks and Moneyball’s 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.