Balls Deep vs. Who’s Your Daddy
ON PETITION FOR WRIT OF CERTIORARI FROM
THE SOUTHWEST FANTASY BASEBALL LEAGUE
Decided February 24, 2014
Cite as 6 F.J. 1 (February 2014)
A fantasy baseball league called the Southwest Fantasy Baseball League (hereinafter referred to as “SFBL”) is comprised of 12 teams and has been in existence since 2010. The SFBL is a mixed AL/NL dynasty league where each team must keep a minimum of ten (10) players from one season to the next within its 28-man roster. Each individual player may be retained by the same team for a maximum of five (5) years before returning to the free agent pool and being eligible to be drafted again.
As with many rotisserie leagues, the SFBL 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 this roto league.
The SFBL has a constitution which contains provisions for making trades and the process by which they are approved. The rules state, in pertinent part:
Article VII – Trades
1. Trades are permitted between teams and must be processed through the league’s website. This includes both teams accepting the proposal.
2. All trades will be approved automatically unless there is suspicion of collusive activity between the parties. Such suspicions will be raised to the SFBL commissioner who shall initiate an investigation into the matter. Collusive activity includes, but is not limited to, an offering of financial incentives, quid pro quo arrangements to reciprocate at a later date, wholly uneven and lopsided trades, or any other intentional manipulation or circumvention of the league rules.
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7. Compensation for trades may include draft picks in any subsequent year.
On February 23, 2014, a trade was made between Balls Deep and Who’s Your Daddy. Balls Deep traded Robinson Cano (2B-SEA, in his final year of protection) and a 3rd round draft pick in 2015 to Who’s Your Daddy in exchange for Xander Bogaerts (SS-BOS, eligible to be protected for three more years, a 2nd round draft pick in 2014, and a 1st round draft pick in 2015.
After the trade was agreed to by the teams, two other teams in the league raised concerns to the SFBL commissioner that this trade was wrought with collusion between Balls Deep and Who’s Your Daddy. The commissioner initiated an investigation into the matter and concluded that there was no collusive activity and subsequently approved the trade. On February 24, 2013, one of the dissenting league members submitted this case to the Court claiming that the trade should have been rejected because of collusion.
(1) Should the trade between Balls Deep and Who’s Your Daddy be upheld?
The SFBL is governed by a constitution which explicitly states the league’s rules concerning trades and the process for approval. The Court always advocates for leagues to have a written constitution because it provides all league members with actual notice of the rules and shifts the burden onto them to be in compliance. Shawn Kemp is My Daddy vs. Fantasy Basketball League Commissioner, 2 F.J. 24, 25 (October 2010). Unless there is a documented dispute with the commissioner or timely challenge to the rules, league members should be bound by such rules. Rubik’s Pubes vs. League Commissioner, 4 F.J. 98, 100 (June 2012). In addition, barring extenuating circumstances that would justify a deviation, the written rules and guidelines should be strictly adhered to. See Justin Verlander’s School for People Who Don’t Pitch Good vs. Angel Pagan Worshippers, 3 F.J. 105, 106 (August 2011).
It is well-established law that people who participate in fantasy leagues should be given the freedom to manage their teams according to their own preferences. Whether success is bred from that individual’s decision-making is purely left to some skill, luck, dedication, and savviness. See 4 Ponies vs. Carson City Cocks, 3 F.J. 13 (May 2011).
When presented with a dispute over the fairness or equitability of a trade, the Court will evaluate the objective merits of a deal and ensure that the integrity of the league is maintained. Victoria’s Secret vs. C-Train, 2 F.J. 32, 35 (October 2010). Typically, the approval or rejection of a trade is based on whether the deal was made without collusion, has equitable consideration, and comports with the best interests of the league. See 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).
The crux of this appeal is an allegation of collusive activity between the two teams who consummated the subject trade. Collusion is defined as a secret agreement or conspiracy especially for fraudulent or treacherous purposes. See Steel Curtain vs. Rusty Trombones, 3 F.J. 201, 203 (November 2011) (holding that a secret agreement between teams to use the first waiver position as a means to move a player to another team further down the list was collusive because its purpose was to circumvent the established rules).
When presented with allegations or suspicions of collusion, the Court will look at the evidence in the light most favorable to the accused. This is because acts of collusion within a fantasy league are one of the most serious fantasy sports crimes that can be committed and can undermine the integrity of a league more so than almost anything else. See Team Zero vs. Samcro Reaper Crew, 3 F.J. 177, 179 (October 2011).
The two teams who made this trade have denied the allegations of collusion. Without a confession or some form of written proof, the Court will rely on circumstantial evidence and weight the totality of the circumstances to determine whether it is more likely than not that collusion exists. John Doe vs. Richard Roe, 3. F.J. 197, 200 (October 2011). Of course without written proof or verbal confirmation, there is no way to definitely prove the existence of such conduct. But we can draw inferences from the evidence presented and the circumstances surrounding the proposed trade. Tiger’s Blood vs. Hulkamaniacs, 3 F.J. 58, 61 (July 2011).
At first glance, the trade of Robinson Cano in exchange for Xander Bogaerts and two future draft picks looks slightly uneven. Cano is an elite fantasy baseball player because of his substantial contributions at a scarce position like second base. His status as an elite player requires additional scrutiny to ensure that fair compensation is being provided for him. Steelers vs. Patriots, 3 F.J. 218, 220 (November 2011). If the BMFBL was a non-keeper league, then this trade should be immediately rejected because there is such an imbalance between the values provided for only the current season. There would be no reason to consider any long-term ramifications. See Willie McGee’s Beauty Parlor vs. Sizemore Matters, 4 F.J. 29, 30 (April 2012).
However, the SFBL is a keeper league. The analysis for evaluating trades is much different in a keeper league than a non-keeper league. See Grave Diggers vs. Chilidogs, 4 F.J. 5, 8 (January 2012); see also Harem Hawkings vs. Harbor Yankees, 4 F.J. 40, 42 (April 2012) (holding that a more expensive player could be financially prohibitive in the long run compared to a cheaper player who offers more financial flexibility). A trade that may look facially uneven or lopsided may receive a different opinion when it is involved in a keeper league. In a keeper league, teams must consider trading established players whose contract may be expiring in exchange for younger, less expensive players and/or future draft picks. The decision-making process in a keeper league must include foresight and long-term considerations as opposed to non-keeper leagues where only the current season is considered. Catfish Hunters vs. Wyld Stallyns, 5 F.J. 4, 6 (February 2013).
Cano is entering the final season he is able to be protected by Balls Deep. According to the league’s rules, Cano would automatically become a free agent at the end of the 2014 season and be eligible for the 2015 draft. This demonstrates Balls Deep’s motivation to obtain some form of compensation for Cano rather than lose him for nothing. Bogaerts will likely not be able to replicate Cano’s statistics this year, but he is a highly-touted young shortstop who can develop into a star player during the course of his tenure on Balls Deep.
Balls Deep arguably obtained even more valuable assets with the acquisition of two future draft picks. Draft picks in subsequent seasons are assets commonly bartered in keeper leagues. See Bald Eagles vs. Weasel D, 3 F.J. 205, 208 (November 2011). In any fantasy baseball league format, Cano is regarded as a 1st round pick. Here, Balls Deep not only obtained an extra 2nd round pick for 2014, but they also acquired an additional 1st round pick in 2015. This puts them in prime position to restock their roster with quality players and be set up for the next cycle of player protection.
From Who’s Your Daddy’s perspective, the acquisition of Cano makes perfect sense. His acquisition demonstrates both a “win now” mentality as well as long-term draft strategy. The record is devoid of both teams’ rosters and where they finished in the standings last year. But the Court can surmise that Who’s Your Daddy believes they are on the precipice of a championship by giving up Bogaerts and two valuable draft picks in exchange for Cano. They can also keep Cano for the next five years as per the league’s rules regarding long-term contracts.
There are clear benefits to both teams despite such a major disparity between the present day value of the exchanged compensation. The trade makes perfect sense from both teams’ perspectives and fulfills the needs of teams within a keeper league. There is also no indication that any collusive activity took place between these two teams. That does not necessarily mean it didn’t take place, but based on the information presented we cannot conclude that the trade was marred by collusion. The fact that the trade is equitable in terms of a keeper league and satisfies the needs of both teams also shifts the pendulum towards the conclusion that there was no collusion. Based on the foregoing, the appeal is denied and the trade should be upheld.
IT IS SO ORDERED.