The Verdict: the court rejects a trade deadline dump trade

SUPREME COURT OF FANTASY JUDGMENT

Stud Muffins vs. Carson City Cocks

ON PETITION FOR WRIT OF CERTIORARI FROM THE INCONTINENT LEAGUE

Decided August 7, 2012
Cite as 4 F.J. 167 (August 2012)

Factual Background

A rotisserie fantasy baseball league called The Incontinent League (hereinafter referred to as “roto league” or “IL”) is an 11-team NL-only keeper league utilizing an auction-style draft and transaction platform. Teams are permitted to maintain up to ten (10) players during each off-season with individual players allowed to be kept for a maximum of three (3) consecutive years under contract. 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 $26.00 draft salary cap, as well as a $36.00 in-season salary cap that is applicable for all teams.

As with many rotisserie leagues, the Incontinent 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.

The Incontinent League submitted a proposed trade between two league members and seeks an opinion on whether the trade should be approved.

Procedural History

The Stud Muffins (“SM”) have made a trade with the Carson City Cocks (“CCC”). SM traded Cliff Lee (SP-PHI, $3.20 with one year remaining on his existing contract) and Jose Altuve (2B-HOU, $0.50 with one year remaining on his existing contract) to CCC in exchange for Bobby Parnell (RP-NYM, $1.00 in the first year of his existing contract), Martin Maldonado (C-MIL, $1.00 in the first year of his existing contract), Wilson Ramos (C-WAS, $0.50 with one year remaining on his existing contract), Logan Forsythe (2B-SD, $1.00 with one year remaining on his existing contract), and Cory Luebke (SP-SD, $1.00 with one year remaining on his existing contract).

Issue Presented

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

Decision

The Supreme Court of Fantasy Judgment typically favors individual fantasy sports participants and teams’ ability to make moves, transactions, and trades. People pay money to participate in fantasy leagues, and generally they should be afforded the freedom to manage their team accordingly. Whether success is bred from that individual’s decision-making is purely left to some skill, luck, dedication, and savviness. See 4 Ponies v. Carson City Cocks, 3 F.J. 13 (May 2011).

It is well documented that there is a different analysis of trades in a keeper league as opposed to a non-keeper league. A trade that may look facially uneven or lopsided could easily pass muster in a keeper league. Trades made between teams in a keeper league need to be analyzed by other factors besides merely comparing statistics. Grave Diggers vs. Chilidogs, 4 F.J. 5, 8 (January 2012). These other factors include salary cap flexibility, contractual status of players, and long-term planning at the expense of the current season. Smittydogs vs. Moneyball, 1 F.J. 32, 33 (June 2010); Winners vs. Seven Shades of Shite, 3 F.J. 97, 102 (July 2011) (holding that team owners in keeper leagues with no hope of contending in the current season must make critical roster management decisions of whether to trade established players to help build for the future).

The Court will evaluate the objective merits of a deal and ensure that the integrity of the league is maintained. See Victoria’s Secret vs. C-Train, 2 F.J. 32, 35 (October 2010). The Court will not undermine a fantasy owner’s ability to manage his/her team unless a deal is unfair or inequitable, ripe with collusion, or not in the best interests of the league. Whether a trade is objectively intelligent or popular will not be part of the analysis. 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.

At first glance, the trade of Cliff Lee and Jose Altuve in exchange for Bobby Parnell, Martin Maldonado, Wilson Ramos, Logan Forsythe and Corey Luebke does not look inequitable. Despite having a sub-par season for an underachieving Phillies team, Cliff Lee is still considered a borderline elite fantasy pitcher, especially in an NL-only league. See Steelers vs. Patriots, 3 F.J. 216, 220 (November 2011). Granted, his value is somewhat diminished based on the fact he only has two wins and has been inconsistent all season. However, his peripheral numbers still warrant this classification.

Lee, winless until July 4 this year, still has a respectable 3.78 ERA, 1.17 WHIP, and 124 strikeouts in 133.1 innings. This may not be what was expected from him this year, but it doesn’t mean he has lost elite status. In an NL-only league, he still ranks amongst the top starting pitching options despite his overall record this year.

Along with Lee, the Stud Muffins traded 2012 All-Star second baseman Jose Altuve. Likely undrafted in most fantasy leagues, Altuve has been a pleasant surprise for an otherwise horrendous Houston Astros team. Through August 6, 2012, Altuve is batting .290 with five homeruns, 30 RBI, 60 runs scored and 21 stolen bases. He has been a viable option in mixed leagues, and certainly one of the better second baseman in an NL-only league.

In exchange, the Stud Muffins acquired a package of five players which include Bobby Parnell, Martin Maldonado, Wilson Ramos, Logan Forsythe and Corey Luebke. Under no circumstances can this package be deemed fair or equivalent value for Lee and Altuve. A player’s value is not necessarily equivalent to the accumulation of several other less valuable players’ statistics. See Team Sabo v. Nub Vader, 3 F.J. 55, 56 (July 2011).

Of these five players, Luebke is arguably the best player and he just underwent Tommy John surgery in May 2012. While it is very likely he will pitch at some point in 2013, it is completely unpredictable when that will be or how effective he will be upon his return. With only one year remaining on his contract, SM will not get much in terms of value for him in 2013.

Bobby Parnell looked to be the future closer for the Mets until he once again proved he cannot handle ninth inning responsibilities over the past six weeks. Blessed with an electric fastball, Parnell doesn’t appear to have the mental make-up to close out games and is destined to be a set-up man for the foreseeable future. He may pick up some vulture wins and have a respectable strikeout ratio, but he does not possess much value beyond that.

SM also acquired two catchers in the deal – Martin Maldonado and Wilson Ramos. Maldonado did a nice job for the Brewers filling in for Jonathan Lucroy while he was on the disabled list. But with Lucroy back and enjoying a career season, Maldonado’s opportunities will be limited going forward. Ramos underwent season-ending ACL surgery earlier this year and is hopeful that he will be back by spring training. He has proven he can hit in the big leagues so he could be a decent fantasy option if he comes back healthy in 2013. But, that will also be his final year under contract so any production or value from him hinges on his pending recovery.

The final player included in the package is Logan Forsythe. Forsythe has been given the opportunity to play semi-regularly for the offensively-starved Padres and he has not produced much, especially since the All-Star break. Any San Diego player is going to be handicapped by the mere fact they play their home games at Petco Park. However, this is even more of an issue for a light-hitting infielder with limited playing time. While he could see time at third base in 2013 if Chase Headley departs, he is by no means a reliable option in terms of fantasy value.

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). There is no dispute that CCC, currently in first place with a 3.5 point lead, will benefit significantly from this deal. Obtaining an ace pitcher like Lee and a solid second baseman such as Altuve greatly increases his chances of maintaining his lead and winning a championship. This is amplified by the fact he did not give away anything of value.

It is difficult to see how this trade helps the Stud Muffins, who are currently in 4th place and only one point out of 3rd place. Even with the loss of Cliff Lee, they still have solid starting pitching with Clayton Kershaw, Jordan Zimmermann, Edinson Volquez, and Trevor Cahill. However, taking Lee out of the lineup will have a detrimental effect on their team.

Additionally, SM sustains a noticeable downgrade at second base by exchanging Altuve for Forsythe. Even more perplexing is the fact that SM will now have five catchers on his roster after this trade. The additions of Maldonado and Ramos do not represent such significant upgrades over the incumbents Michael McKenry, Chris Snyder and Nick Hundley.

The only conclusion the Court can draw is that the Stud Muffins are punting the current season. When a team owner in a keeper league no longer has any hope for contending in the current season, he must make a critical roster management decision of whether to trade off established players. See Winners v. Seven Shades of Shite, 3 F.J. 97, 102 (July 2011). However, when doing so, there must be sufficient and cognizable compensation obtained in exchange for such current assets. Otherwise, a trade will be deemed inequitable and contrary to the best interests of the league if 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. Los Pollos Hermanos v. Little Stumps, 3 F.J. 192, 195 (October 2011).

This trade is so lopsided that it cannot possibly be considered equitable. Lopsided trades throw off the competitive balance of the league and create a slippery slope for future trades. The Court has no issues with the idea of trading superstar players so long as the package in return is equitable and makes sense given the needs of both teams. See 4 Ponies v. Beaver Hunters, 3 F.J. 26, 29 (June 2011). Moreover, the Stud Muffins don’t even get the benefit of salary cap flexibility because they are actually taking on an additional $0.80 by making this deal. There is no discernible benefit to the Stud Muffins based on the compensation provided by CCC.

It is normally acceptable for teams in keeper leagues to make trades that do not have equivalent present-day value. However, a deal that is so completely lopsided and goes against the best interests of the league will be rejected. See Smittydogs vs. Moneyball, 4 F.J. 57 (May 2012) (rejecting a trade of Ryan Braun and Edwin Jackson in exchange for Randall Delgado, Dee Gordon and Bobby Abreu); Team Sabo vs. 4 Ponies, 4 F.J. 50 (May 2012) (rejecting a trade of Joey Votto and Tyler Clippard in exchange for Drew Stubbs, Francisco Rodriguez and Starling Marte). Based on the foregoing, the Court rejects this trade and deems it inequitable and contrary to the best interests of the league.

IT IS SO ORDERED.