Fantasy Judgment: Balls Deep vs. Who’s Your Daddy
SUPREME COURT OF FANTASY JUDGMENT
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)
Factual Background
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.
* * * * * *
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.
Procedural History
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.
Issue Presented
(1) Should the trade between Balls Deep and Who’s Your Daddy be upheld?
Decision
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.
Michael A. Stein, Esq. is the Chief Justice of Fantasy Judgment, the industry's premier dispute resolution service. Fantasy Judgment resolves league conflicts by issuing legal decisions resolving cases fairly and expeditiously.
that’s a lot of words. what are their rosters? as much as everyone loves Xander, Que red sox hate mail here, who’s to say he isn’t the next Travis Snider? what’s the competition in their divisions? will cano’s new owner finish with a record that influences where this picks will be made? what future picks do they hold? is this the foundation of a future trade? the links are fun but the questions are many.
The decisions are based on what information the parties provide. Rosters, divisional competition, and future picks owned were not disclosed.
Travis Snider is the guy you choose as the cautionary tale that some prospects disappoint? Just a really, really weird guy to name in that spot as any type of comparison.
Not sure if it’s queue or cue, but it’s definitely not que.
Shorter headline, please. It’s what yoy see from grandma, who doesn’t quite know how to use a computer or understand how the internet works.
Duly noted. That’s what I get for letting my Nana use my computer.
Which is also true of Supreme Court justices.
Thanks Michael. Wrest that thing away from Nana, she can get her Solitare and MS Outlook elsewhere. (Thanks for taking the suggestion to heart in the good-natured manner intended.)
(We still love Nana.)
Nana appreciates all of the love. I sincerely appreciate any comment given back to me whether positive, negative, humorous, sarcastic or in another language. I realize that my style and content is not everyone’s cup of tea, and that is ok. Posting an entire decision here may not be the best way to go about this, so I fully recognize that. But I wanted to let people know that a service like this exists and that I will be writing about fantasy disputes and issues that come up in leagues.
I suggest that if you decide to continue posting them, you consider cases that have more subtlety to them. I enjoy the style, but it’s kind of overkill for a trade that’s very obviously OK.
Doesn’t seem like collusion, just a huge overpay for Cano. 3 years of Bogaerts + a 1st and 2nd round pick for 1 year of Cano + a 3rd round pick? Don’t understand why anyone would give that up for Cano, especially after the move to Seattle, but to each his own I guess.
Apparently Cano’s free agent clock resets due to the trade.
This strikes me as the sort of collusion-encouraging rule that should be avoided.
I double checked to see if I had clicked on NotGraphs accidentally.
Definitely have to trim that title down, and the XB side is a clear winner in a fair deal.
Bogaerts floor is a middle tiered SS with 3 years of eligibility + a 2nd rounder next year and moving from 3rd to 1st round in 2015. All for a 31 year old 2b moving to a power suppressing park. He’s still the best 2b going in this year, but his HR are going to be down, and with his supporting cast if nobody gets on, less RBI. Fairly easy to see some noticeable regression here.
So, the trade is a reasonable deal for present vs. future value AND there’s no evidence of collusion? Case closed. I have fun with this, but I’m not even sure how this is difficult.
P.S. – Someone went to law school…where’d you come up with those citations?
The citations comes from previous cases I have adjudicated at http://www.fantasyjudgment.com. Some leagues send all of their trades for review and approval, so even though the decisions are relatively obvious they still receive the same time and attention as contentious deals.
Nice opinion. Although the league’s constitution or rules define collusion, the definition of collusion used by the court in Steal Curtain is also cited. Under which was definition was the trade evaluated?
The league’s definition of collusion was more of a list of examples that could imply collusive activity. Typically we will defer to a league’s rules or constitution (if one exists). The Court’s definition of collusion is a catch-all generalization of fraudulent activity between teams, so the league’s definition would fall within those parameters if any of them existed. We did not believe there were any arrangements between these two teams which would qualify as collusive activity either under the league’s rules or the cited definition.
If the league had provided the rosters of the teams involved in the trade, would the court have considered them? What if the rosters of the other teams in the league had been? If the court would have considered them, is the trade adequately presented for arbitration?
If we are given the rosters of the teams involved in the trade, then we would analyze the needs of both teams to see whether a trade makes sense from both teams’ perspectives. It is just another element of the analysis. It is rare that a trade would be rejected, but one circumstance that could lead to a trade being rejected is if we cannot objectively ascertain any benefit being afforded to one of the teams. The rosters of other teams in the league who aren’t involved would not be relevant to the analysis. Typically we will ask for any and all information that could be helpful to reaching a decision. But sometimes our clients do not provide everything, so we have to base the decisions on what we do know and then draw inferences where necessary.
I had no idea fantasyjudgment was a thing. Now I know it is, and I am glad. I’ve read actual opinions from actual judges that weren’t that well-reasoned.
Thanks you…your comments are much appreciated. We are here to help if you or your league(s) require our services.
i love FG, and i love RG, and i have never read an article i didn’t like – until this one. lots and lots of words, and for what reason? two teams in fantasy baseball made a trade. wowzers. i am not trying to be a dick, but i have no idea why this article was written and then posted on the internet.
Don’t worry; it seems you can be a dick without even trying.
Presumably my high school Halo-playing comrades, whose chief virtues included being good at Halo without even trying, would find such a trait worthy of admiration.
I actually agree with at least part of the point Tyke is making. I read the article, and gradually figured out that it was about some sort of legal entity judging whether a fantasy trade was collusive or not, but it never presented any point of view that made it clear why this information was being presented.
Here are some possibilities:
1. The author (or FanGraphs) is trying to market or promote a product (arbitration for fantasy leagues).
2. To educate us on how to reason about possible collusion in our own leagues.
3. To demonstrate how to design clear rules for our leagues so collusion can be adjudicated fairly.
4. To demonstrate by example how one league’s unfair, collusive trade may be another league’s fair exchange, depending on keeper rules and the value of draft picks.
5. To illustrate that just because our first reaction is that a trade may be collusive does not mean it may not actually be fair, or at least fair in the mind of the apparent ‘losing’ owner.
6. To assess the future value of Xander Bogarts vs. Robinson Cano in a keeper league. This is the article a lot of people here would have enjoyed most.
It’s an article different from any I’ve seen here before, written in a style different from any I’ve seen here before, from an author whose name I don’t recognize, that jumps into description of a legal battle without providing an angle or sufficient context.
It’s not uninteresting, but I shared Tyke’s confusion.
Wait, so one team can keep a guy for five years and then when they’re not allowed to keep him any more, they can trade him to another team who can keep him for another five years? That is one weird rule. Leagues where players have different inherent values to different teams make me nervous.
Although now that I mention it, I want to see a 10-team 5×5 league where each team gets double points for a different category. That sounds amusingly chaotic.
Do you tell them in advance, or pick them out of a hat at the All-Star break?
I was in a league with a rule like this and it drove me nearly insane.
The top teams were able to just continuously shuffle their stud keepers among themselves so no top talent was ever draft eligible. And the different inherent value problem makes it impossible to really reject any trade based on collusion. In most of the trades the biggest value gained was added years to the expiring keeper contract and that value magically appeared out of nowhere.
We have since fixed it, saving me years of therapy!
I am firmly with Mike and Tim P here . . . the league’s rules re. a player’s protection clock getting reset once a trade occurs needs a total rethink. Have a clearly defined service clock, and when it expires the guy is back in the draft, period. A contending team would still want to trade for an expiring Cano; he just would not get the additional benefit of keeping Cano for 4 more years.
Thanks for the insight.
As commissioner of an established keeper league, it’s always interesting to see the issues/disputes that arise in other leagues…and to see if there is something you can do in advance(rule change or whatever)to keep them from happening.
BTW..From the criticism, it appears some of the people in the thread have never read a law journal or even an abstract from any major professional publication.
The idea that internet “style” is standardized and its format is the appropriate form to present in-depth info is hilarious.
Hey, this title and article are now 100 times better. I still would prefer less of the legalese at the beginning, in favor of moving more quickly into the discussion of relative values of players and draft picks, but the formatting and presentation now make it easy to parse.
i was really hoping this would have died with THT fantasy. just unbearable to read.
Someone is getting some use out of his law degree. I would sell mine back at a loss if I could.
1800 words to list the trade and essentially say: “It’s a keeper league, so yeah, sounds about right”
I like the theory of this column, but rulings on trades are not interesting unless you are involved. Opinions on things that could affect other leagues might be though. The legal jargon is cute, I guess, but ultimately unnecessary.
i don’t see the conflict here. if you’re going balls deep on someone, you’re probably already their daddy.
Well played.
Sorry, but this:
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.
makes no sense. If collusion is so terrible, why isn’t the evidence viewed in the light most favorable to the accuser?
Excellent question. Much like a motion for summary judgment in real court (which disposes of the entire case procedurally), there are serious consequences to finding that collusion exists. Anyone can make accusations of collusion simply by linking circumstantial evidence or innuendo, so we want to make sure we give the accused party a fair shake in reviewing the evidence. As an independent 3rd party, we have no way of knowing for sure that collusion took place unless we have a confession or written proof. Chances are we will not have that evidence. Because we have to draw conclusions and inferences, it is important that people be given the benefit of the doubt before strong penalties are recommended or enforced.
I liked this article. It wasn’t informatie really, but it was a pretty fun read, and I’m fine with having those on ocassion.
Thanks very much.
For me – this all comes down to how much money is at stake and how close the guy getting Cano is to winning the league.
If there’s a big payout (say $1,000+) and he has a lot of the top players in the league for 2014 – then it might be worth overpaying now to win this year. Especially if the “holding clock” for some of his best players is about to expire too.
He might be the Marlins – stock up, win the league and then go into a complete rebuild.