On Tuesday morning, the Associated Press reported that the Major League Baseball Players Association may file a grievance against Major League Baseball club-owners for allegedly colluding in the market to sign free-agent players during the 2009-2010 off-season. One reason why the MLB players union seems to believe that club-owners have engaged in collusion is because player salaries rose only by 1% last season, even though total league revenues have increased at an annual rate of 7.6% over the past three years .
Another reason why the MLBPA may be concerned about collusion is that MLB club-owners have a long history of colluding in the free-agent player market. For example, in my 2008 Wayne Law Review article, "Moving Past Collusion in Major League Baseball: Healing Old Wounds and Preventing New Ones," I discuss how three arbitration decisions from the 1980s found MLB club-owners to have colluded against players' rights. One esteemed labor arbitrator, George Nicolau, even found Commissioner Bud Selig to have been directly involved in collusion during the 1986-87 off-season (seepages 619-20).
With this week's newest collusion concerns, the MLBPA now has to decide whether to file a formal labor grievance over three separate, outstanding sets of claims:
Then, there are similar allegations from the 2008-09 off-season, over which the MLBPA, one year after announcing its concerns, still has not filed a grievance.
For the second consecutive year, FantasyPros911 held its "experts" fantasy league auction. However, this "experts" league is unlike all others in two respects. First, the league has an upper and lower division and uses a 2-team promotion/relegation system similar European soccer. Second, there is a real prize for the league winner--a cruise for two. Thus, all owners have the incentive to give it their best shot.
In 2009, SportsJudge.com placed second in the Blogger Division (NL-Only), earning us a promotion to the group of Experts (AL-Only).
This year, we are facing off against a collection of experts that features Patrick DiCaprio (2009 winner, FantasyPros911, MIT graduate); Jason Mastrodonato (2009 runner-up, Mastersball.com) and Adam Ronis (beat writer, New York Newsday).
Here is our 2010 AL-only "Experts" team:
C Jarrod Saltalamacchia 4 C Dioner Navarro 4 1B Miguel Cabrera 35 2B Robinson Cano 25 3B Garrett Atkins 5 SS Derek Jeter 25 2B/SS Dustin Pedroia 28 1B/3B Mark Teixeira 36 OF B.J. Upton 24 OF Alex Rios 20 OF Jose Guillen 7 OF Felix Pie 2 OF Willie Bloomquist 3 DH Willy Aybar 4 P Phil Coke 3 P Brad Bergesen 2 P Gil Meche 5 P Jake Westbrook 2 P Matt Guerrier 2 P Jeremy Bonderman 2 P Fernando Rodney 2 P Ryan Rowland-Smith 3 P Dustin McGowan 1 BE Freddy Garcia 2 BE Kyle Drabek 1 BE Brandon Morrow 4 BE Joe Nathan 2 BE Andruw Jones 4 BE Dontrelle Willis 2 BE Bill Hall 1
Petitioner, by and on behalf of the members of Balls and Strikes League seeks review of a trade that was executed between Respondents Duro Sin Vase in your grill!! and 2SWEET 4LIFE. The league should allow the trade of Jose Reyes (NYM, SS) and Jose Valverde (HOU, RP) for Javier Vazquez (ATL, SP), Jhonny Peralta (CLE, SS) and Nelson Cruz (TEX, OF) for the reasons set forth below.
THE LAW & BACKGROUND
In the absence of a league constitution stating a contrary rule, this Court applies a standard that asks whether a trade adequately benefits each of the teams (SeePublic Opinion No. 101, Big Red Rockers v. Big City Bombers). Where a trade could realistically enable both teams to move up in the standings, it is presumed that both teams adequately benefit (See Unpublished Opinion No. 468-T, Balls & Strikes League v. Ever-Lastings and 2 Legit 2 Quit).Indeed this league well knows this Court’s standard of review.
In examining whether a team derives some benefit from a trade, the standard requires the Court to consider not only the quality of the players, but also the context of the trade. In addition, one of the fundamental rules that this court honors is that each owner/manager in a league, by virtue of their participation in a league, has the discretion to manage their team as he sees fit.Trades between teams on opposite ends of standings are always highly scrutinized by league members—and rightfully so. And while struggling teams should actively seek to improve through trade, those teams are not excused to make objectionable trades.
Nonetheless, in this Court’s view, this particular trade is not unreasonable and satisfies the adequately beneficial standard.The trade must be upheld.
THE PROPOSED TRADE
The proposed trade is a 3-for-2 swap, as follows:
Duro Sin Vase in your grill!! proposes to send to 2Sweet 4Life (current 2009 statistics in parentheses):
Most would agree that the “best player in the trade” is Jose Reyes.Most people would be right.He remains a consensus first round draft pick.He has shown to be streaky at times, but in a rotisserie league such as this one, that matters little. Reyes’ stolen bases are there, but the rest of his numbers have not caught up yet this season.The Court takes judicial notice of the fact that the trade was executed prior to the news that Reyes re-aggravated a calf injury, and does not factor that into its decision.
Meanwhile, Javier Vazquez has been very successful so far in his first year with Atlanta.Maybe it’s the National League hitters, or maybe it’s just the raucous fans in Atlanta.In any event, his K/9 ratio is outstanding and the ratios are solid.Elsewhere, Peralta has been underachieving based on his numbers from last year where he hit 23 home runs and recorded 89 RBI to go along with a .276 batting average.Nelson Cruz was pegged by many to have a “breakout year” and after getting off to a torrid start he’s cooled off quite a bit.But the season is still young.As for Valverde, he should return to his closer role upon his return (although LaTroy Hawkins has been serviceable in his stead), although Rotowire.com reports that “Valverde's ETA is still several weeks away. Don't expect to see him on the hill until mid-June at the earliest.”
Here, 2SWEET 4LIFE is ranked third to last K’s and WHIP; he’s sixth in wins and next to last in ERA.Based on that alone, and considering the league’s rules limiting a team’s starting pitcher starts to 180 (making quality count much more than quantity), and upon reviewing 2SWEET’s roster, it appears he needs a solid starting pitcher.Vazquez would help him out immensely and should boost his position in each of the aforementioned pitching categories.2SWEET is already third-to-last in stolen bases, and so the loss of Reyes, whose greatest contribution is stolen bases, would have a marginal effect on 2SWEET’s position there.2SWEET is clearly addressing his greatest need.
In addition, 2SWEET gets Peralta who will aid his power if the Indians slugging infielder, as expected, eventually manages to get himself going.Nelson Cruz should contribute at utility as well. When Manny returns from his estrogen-use hiatus it might put 2SWEET in a position to move an OF.And Valverde is no sure thing to get healthy and finish the year as closer, either.But the deal would leave 2SWEET with only one actual closer and two speculative, used-to-be closers.The loss of Valverde has questionable impact.
Some might argue that 2SWEET “could have gotten more” for Reyes.Maybe that’s true, but maybe it’s not. An owner can’t pull teeth and is entitled to make the moves he sees fit to alter his team into a more competitive squad.All in all, this Court feels that this trade is adequately beneficial to both teams.
HOLDING
For all of these reasons, the league should uphold the trade.
This dispute involves whether the Commissioner of the Hampshire Baseball League was within his rights to allow one of its teams, the Cedarburg Tigers, to submit a late bid for free agent second baseman Emilio Bonifacio.Based upon a review of the facts, this court rules that it was not proper for the Commissioner to extend the bidding period beyond the stated 24-hour period.Therefore, the court orders the rights to Emilio Bonifacio to revert to the Philadelphia Freedoms—the team that had submitted the highest bid at the time the player auction officially expired.
While the court recognizes this case is complicated by the Commissioner’s original error in prematurely announcing the auction for Bonifacio closed, the Cedarburg Tigers nevertheless are barred from challenging this original decision under the Doctrine of Laches.This is because the Tigers had failed to bring such a challenge to the Commissioner’s attention within a reasonable period of time.
THE DISPUTE
The Hampshire League Free Agent Auction Rule:
The Hampshire Baseball League is a mixed league (AL & NL) fantasy baseball league, currently in its ninth season.The league maintains a free agent auction rule, which allows teams to bid for free agent players using an in-season auction bidding process.This means, each time a team seeks to sign a free agent, that team must place a bid for the player.The other teams then have a chance to top that bid.
From the league’s first season in 2001 through 2007, Hampshire League maintained a free agent bidding period of just four hours.Then, in 2008, the Hampshire League changed its rules to allow for a 24 hour bidding period.
The 2009 season marked the Hampshire League’s second season under its new 24-hour bidding procedure.All league owners were on notice of the league bidding procedure having competed in the league during the previous season,
The Bidding for Emilio Bonifacio:
On April 7, 2009, at 8:00 A.M., the Cedarburg Tigers called to auction Florida Marlins second baseman Emilio Bonifacio with a bid of $0.25.Two hours later, at 10 A.M., the Philadelphia Freedoms topped that bid with a $2.00 offer.Then at noon, the league Commissioner posted a message on the league message board declaring the auction “CLOSED” and awarded Bonifacio’s rights to the Philadelphia Freedoms.This decision, however, was incorrect.Pursuant to the current league rules, the auction should have lasted for twenty-four hours—not four hours.Therefore, other teams should have still had the opportunity to top the Freedoms’ bid.Nevertheless, no team challenged the Commissioner’s decision to close the bid process early—even though all teams in the Hampshire League played under the 24-hour auction rule the previous season.
Thereafter, on April 9 at 10 A.M., the Commissioner realized himself that he had improperly closed the bid period on Bonifacio.In an attempt at fairness, the Commissioner then unilaterally decided to offer the Cedarburg Tigers additional time to match the Freedoms bid on Bonifacio, which they did.The Commissioner then sought to award Bonifacio to the Cedarburg Tigers.
The Parties Arguments:
Both parties submit somewhat reasonable arguments as to why they should be allowed to keep the rights to Emilio Bonifacio.The Cedarburg Tigers contend that they might have matched the $2.00 bid for Bonaficio; however, he “figured that [the commissioner] would know the rules [so he] respected that and moved on.Meanwhile, the Philadelphia Freedoms contends that “[the league] rules are very clearly written ….The other owner should have known the rules. If he did not know the rules, he could have simply looked at them. They are posted on our website.”Nevertheless, neither of these arguments resolves the situation in a perfect manner.
Here, the dispute amongst the parties involves the length of the free agent bidding period.All parties agree that the league constitution states this period shall last for just twenty-four hours.However, the parties disagree about whether the Commissioner is allowed to increase the length of this period as a way to correct for his own earlier mistake in declaring the period prematurely complete.
This court recognizes that there may exist an exception to the general rule for certain extremely usual circumstances could toll a constitutionally stated bidding period.For example, potential reasons why a commissioner might be allowed to toll the twenty four hour period, in theory, might include an outage on the site that collects bids, or a temporary suspension of league operations.
While this court is mixed on the issue of whether a commissioner’s inaccurate statement could ever toll a bidding period for a free agent, the court is unanimous that the commissioner may not unilaterally toll the period in a situation, such as is here, where no party even requested tolling until the bid period had concluded.This conclusion is based on the equitable Doctrine of Laches, which this court has applied on several previous occasions.(See Public Opinion No. 2959-T, Commissioner v. Teams 1, 2, and 3).This is a legal doctrine that, as matter of fairness, prevents an unduly slothful party from thereafter seeking a remedy.
Here, it would be unfeasible to allow a Commissioner to indefinitely extend a bidding period based on his own mistake given that no league owner researched the Commissioner’s decision and brought it to his attention during a reasonable period of time.Indeed, the Cedarburg Tigers had access to the rules.The Cedarburg Tigers could have checked the rules, and brought their grievance to the Commissioner before the 24-hour bid period lapsed.However, they chose not to do so, and instead simply proceeded with the season without having Emilio Bonifacio on their roster.As a result, it was improper for the Commissioner, thereafter, to conduct his own independent investigation and award a remedy to the Cedarburg Tigers.
Indeed, the Hampshire League Commissioner attempted to extend the bid period for the Cedarburg Tigers by only a short amount of time.However, allowing such an extension would naturally lead the court down a slippery slope that it finds inappropriate.What if the Commissioner discovered his error one week later?One month?Three months?This court is simply not going to go down that path.
If the Cedarburg Tigers had correctly believed they had an additional twenty-hour window in which to bid on Bonifacio, they should have made that known within this twenty-hour window.By waiting longer than that period, as a matter of fairness and certainty, they forever waived such rights, if any.
Holding
For the foregoing reason, this court unanimously overturns the late bid submitted by the Cedarburg Tigers and awards the rights to Emilio Bonifacio to the Philadelphia Freedoms.
Disclaimer: Information contained on this site is for informational or recreational purposes only. Nothing written is intended to serve as legal advice or legal counsel.
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On Tuesday morning, the Associated Press reported that the Major League Baseball Players Association may file a grievance against Major League Baseball club-owners for allegedly colluding in the market to sign free-agent players during the 2009-2010 off-season. One reason why the MLB players union seems to believe that club-owners have engaged in collusion is because player salaries rose only by 1% last season, even though total league revenues have increased at an annual rate of 7.6% over the past three years .
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