New Fantasy Judgment decision – fantasy baseball trade (Justin Upton)

SUPREME COURT OF FANTASY JUDGMENT

4 Ponies v. Nub Vader

ON PETITION FOR WRIT OF CERTIORARI FROM THE INCONTINENT LEAGUE

Decided June 8, 2011

Cite as 3 F.J. 30 (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 4 Ponies have made a trade with Nub Vader.  The 4 Ponies traded Brandon Beachy (SP-ATL), Domonic Brown (OF-PHI), and Logan Morrison (OF-FLA) to Nub Vader in exchange for Cameron Maybin (OF-SD) and Justin Upton (OF-ARZ).

Issue Presented

(1)   Should the trade between the 4 Ponies and Nub Vader 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. 

The Court has always held that the approval or rejection of a trade is based purely on its fairness, free from collusion, and in the best interests of the league.  Whether a trade is intelligent or popular will not be part of the analysis.  The virtue of a trade is measured in both quantifiable criteria and subjective needs of the teams involved.  See Carson City Cocks v. Stud Muffins, 3 F.J. 23, 24 (May 2011).

At first glance, the trade of Brandon Beachy, Domonic Brown and Logan Morrison in exchange for Cameron Maybin and Justin Upton looks fair.  Justin Upton is the best player involved in this trade so the equitability of the deal will focus on him and what was given in return.  Uptonhas emerged as one of the best all-around players in both real and fantasy baseball.  What makes him so appealing in roto leagues is his power and speed combination that only a handful of players possess.  Maybin was projected to be the same type of player but has yet to really put it all together in his young career.  Clearly the 4 Ponies, currently in 2^nd place, are looking to add more power and speed to their roster.  In exchange, they have traded two other young outfielders in Brown and Morrison.  Both of them are highly touted as well and have performed well in their brief careers.  However, neither possesses the same power/speed combination that Maybin and Upton have.  Despite that, Morrison has been entrenched as the Marlins everyday left fielder and is right in the middle of their lineup.  Brown was only recently called up to the Phillies due to injuries and ineffectiveness of their current crop of outfielders.  He has not played much against lefties, but it is expected that he will be worked into an everyday position as the season goes on.  In addition to Morrison and Brown, Nub Vader is acquiring Braves’ starting pitcher Brandon Beachy.  Beachy is currently on the disabled list with an oblique injury but is projected to come back within the next couple weeks.  He had pitched well before the injury and will be a solid addition to Nub Vader’s staff which is sorely in need of help. 

Statistically, the trade favors 4 Ponies by virtue of Upton and Maybin’s collective performance.  However, it must be taken into consideration that Brown was only recalled a couple weeks ago and Morrison missed several weeks due to injury earlier in the season.  This partially explains why their statistics are not nearly as close, which is demonstrated in the table below:

Player	AVG.	HR	RBI	Runs	SB
Justin Upton	.272	11	30	36	11
Cameron Maybin	.254	5	15	24	7
Domonic Brown	.283	1	6	6	1
Logan Morrison	.295	7	21	19	1

Over the course of a full season with full playing time and no injuries, all players involved in the trade are projected to have more equivalent statistics.  The evaluation must take into account why there is such a discrepancy at the time the trade is made.  As previously stated, Brown was in the minor leagues and Morrison was injured.  Now that all players are active and healthy, the trade can be viewed through an appropriate lens which shows it is equitable.

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 at issue involves four outfielders and one starting pitcher.  The exchange of two outfielders for two outfielders essentially cancels each other out in terms of specific needs for each team.  The fact thatUpton is in the trade and is the best player involved necessitated the inclusion of Beachy.  Despite being injured, Beachy will be a welcome addition to Nub Vader’s pitching staff which is severely lacking in quality starters (he currently has J.A. Happ, Jeff Karstens, Jake Westbrook, Mike Leake and Joe Blanton).

In terms of keeper league status and salary cap value, this trade includes a large disparity in monetary value.  Beachy,. Brown and Morrison cost $0.50 each.  Maybin also costs $0.50 andUptoncosts $4.20.  This means that Nub Vader is gaining $3.20 in salary cap space which represents almost 10% of the Incontinent League’s $36.00 salary cap for each team.  In terms of contract status,Uptonis in the first year of his contract so the 4 Ponies will have him for another two years after this.  On the other hand, both Brown and Morrison only have one year left on their contracts.  Presumably, Nub Vader will be able to use his newly-acquired salary cap space to replenish his team in the 2012 draft.  Beachy is in the first year of his contract, and given his youth and initial success with the Braves, Nub Vader will certainly benefit from having him locked up for another two years. 

As referenced in Smittydogs v. Moneyball, 1 F.J. 32, 34 (June 2010), the dichotomy between the 4 Ponies and Nub Vader’s motivations is precisely why the Court must look at trades in keeper leagues differently than non-keeper leagues.  If this trade had been made in a non-keeper league, the Court would still likely approve it. 

It should be reiterated that the Court typically favors a league owner’s ability to make trades and manager the roster according to his/her own preferences and judgments.  When a person pays money to participate in a fantasy league, the presumption is that he/she is permitted to make whatever decisions they feel are best for their team.  Based on the foregoing reasons, the Court hereby decides that the subject trade is fair and even.  The trade should be approved as it comports with the best interests of the league.

IT IS SO ORDERED.