2013 NATIONAL BASEBALL ARBITRATION COMPETITION

2013 NATIONAL BASEBALL ARBITRATION COMPETITION Ike Davis v. New York Mets Submission on Behalf of Ike Davis Prepared by Team 4 Midpoint: $2.7 million ...
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2013 NATIONAL BASEBALL ARBITRATION COMPETITION Ike Davis v. New York Mets Submission on Behalf of Ike Davis Prepared by Team 4 Midpoint: $2.7 million

Table of Contents I.

Introduction and Request for Hearing Decision ………………….……………….… 1

II.

Quality of the Player’s Contributions During Past Season ………………………….. 2

III.

Length and Consistency of Career Contributions ………………………………….... 3

IV.

Comparative Baseball Salaries .……………………………………………………... 5

V.

Existence of Physical or Mental Defects .…………………………………………… 8

VI.

Recent Performance of the Club .……………………………………………...…….. 8

VII.

Past Compensation .………………………………………………….……………..... 8

VIII.

Conclusion .…………………………………………………...…….……………….. 9

I.

Introduction and Request for Hearing Decision This brief analyzes the contributions of first baseman Ike Davis (“Davis” or the “Player”)

to be considered for his 2013 contract with the New York Mets (the “Mets” or the “Club”). The Major League Baseball (“MLB”) Collective Bargaining Agreement (“CBA”), agreed between the MLB Players Association (“MLBPA”) and MLB Clubs, sets out the criteria to be considered in this hearing.1 The CBA’s set criteria are: (1) quality of contributions to the club during the past season, (2) career contributions, (3) past compensation, (4) comparative baseball salaries, (5) physical defects, and (6) recent club performance.2 For any comparisons, contracts of players with Major League service time not exceeding one annual service group above the Player’s annual service group shall be granted more weight. Evidentiary submissions are subject to the limitations put forth under the CBA Section VI (E), Sub-section 10(b). These limitations include: (1) “the financial position of the Player and the Club,” (2) “press comments, testimonials or similar material bearing on performance of either the Player or the Club, except that recognized annual Player awards for playing excellence shall not be excluded,” (3) “offers made by either Player or Club prior to arbitration,” (4) “the cost to the parties of their representatives, attorneys, etc.,” and (5) “salaries in other sports or occupations.”3 Davis qualifies for arbitration as a “Super Two Player” because he has 2.168 years of service time, has accumulated at least 86 days of service during the most recent season, and is in the top 22% in total service of players with between two and three years of Major League service. Based on the criteria laid out in the CBA, Ike Davis is entitled to a salary exceeding the $2.7 million midpoint and he respectfully requests the panel find he is entitled to an award of $3 million.                                                                                                                 1

MLB Collective Bargaining Agreement. “2012-1016 Basic Agreement,” Art. VI (E) § 10(a)-(b). Id. at § 10(a). 3 Id. at § 10(b)(i-v) 2

 

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II.

Quality of the Player’s Contributions During Past Season In the 2012 season, Davis demonstrated that he is an offensive and defensive leader for

the Mets organization. He led the Mets with 32 home runs and was tied for the Club lead in games played.4 He also finished in the top five in the National League (“NL”) for home runs, and third in at bats per home run.5 Additionally, Davis ranked second on the team in runs scored and runs batted in (“RBI”), ranked third in doubles, walks, and slugging percentage (“SLG”), and finished fifth in hits, OPS, and offensive wins above replacement (“OWAR”).6 Davis scored more than 10% of the Mets runs in the 2012 season.7 Further, he accounted for over 19% of the Mets offense for the 2012 season.8 TABLE 1: Ike Davis (1B) 2012 Season Offensive Statistics9 MLB Service Time: 2.168 G R H 2B HR RBI BB 2012 156 66 118 26 32 90 61

BA .227

DOB: March 22, 1987 OBP SLG OPS .308 .462 .771

Defensively, Davis had the highest fielding percentage among Mets’ players who played in 75 games or more with a .994 fielding percentage.10 He was also fifth on the team in

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Ike Davis Statistics and History, Baseball-Reference, http://www.baseballreference.com/players/d/davisik02.shtml#contracts. 5 Id. 6 New York Mets Batting Stats – 2012, ESPN, http://espn.go.com/mlb/team/stats/batting/_/name/nym/cat/OPS/newyork-mets. 7 Id.; Ike Davis Statistics and History, Baseball-Reference, http://www.baseballreference.com/players/d/davisik02.shtml#contracts. 8 Calculated through: (Davis’ RBIs – Davis’ HRs + Davis’ runs scored)/(Total Runs scored by the Mets in 2012); New York Mets Batting Stats – 2012, ESPN, http://espn.go.com/mlb/team/stats/batting/_/name/nym/cat/OPS/newyork-mets; Ike Davis Statistics and History, Baseball-Reference, http://www.baseballreference.com/players/d/davisik02.shtml#contracts. 9 Ike Davis Statistics and History, Baseball-Reference, http://www.baseballreference.com/players/d/davisik02.shtml#contracts. 10 New York Mets Fielding Stats – 2012, ESPN, http://espn.go.com/mlb/team/stats/fielding/_/name/nym/new-yorkmets.

 

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defensive wins above replacement (“DWAR”).11 Additionally, he was third in the NL for fewest errors committed by a first basemen with only eight.12 III.

Length and Consistency of Career Contributions Davis has shown consistency through his first two full seasons at the major league level,

building off of a notable body of work prior to breaking through into the majors. After being named most valuable player of two different high school all-American games, Davis was selected in the 19th round of the 2005 Amateur Draft by Tampa Bay.13 He decided against signing with Tampa Bay in favor of attending Arizona State University (“ASU”).14 Davis concluded his college career at Arizona State by earning First-Team All-America honors from Baseball America and four other publications.15 After a tremendous three years at ASU, which resulted in Davis being named to the all-decade team for ASU for the 2000s, he was drafted 18th overall by the Mets in the 2008 amateur draft.16 During the 2009 season, Davis was named the Mets Organizational Player of the Year while playing for the Mets Double-A affiliate.17 Davis used this as a springboard to earn his way onto the major league roster less than one month into the following season.18 He started his major league career with a successful rookie season in 2010 that saw him finish seventh in the                                                                                                                 11

Ike Davis Statistics and History, Baseball-Reference, http://www.baseballreference.com/players/d/davisik02.shtml#contracts. 12 Id. 13 Mets select Arizona State University first baseman Ike Davis and University of South Carolina Shortstop Reese Havens in first round of Major Baseball’s First-Year Player Draft, http://newyork.mets.mlb.com/news/press_releases/press_release.jsp?ymd=20080605&content_id=2848803&vkey=p r_nym&fext=.jsp&c_id=nym. 14 Id. 15 Ike Davis Baseball Stats, http://www.baseball-almanac.com/players/player.php?p=davisik02. 16 ASU Baseball All-Decade Team, http://www.thesundevils.com/sports/m-basebl/spec-rel/012610aae.html; Ike Davis Statistics and History, Baseball-Reference, http://www.baseballreference.com/players/d/davisik02.shtml#contracts. 17 NY Mets Player Awards, http://www.milb.com/news/article.jsp?ymd=20090921&content_id=7074718&vkey=pr_t543&fext=.jsp&sid=t543. 18 Ike Davis Statistics and History, Baseball-Reference, http://www.baseballreference.com/players/d/davisik02.shtml#contracts.

 

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National League (“NL”) Rookie of the Year voting, while also being named to the Baseball America All-Rookie Team.19 TABLE 2: Ike Davis (1B) Career Statistics20 MLB Service Time: 2.168 G R H 2B HR 2010 147 73 138 33 19 2011 36 20 39 8 7 2012 156 66 118 26 32 Career 339 159 295 67 58

RBI 71 25 90 186

BB 72 17 61 150

BA .264 .302 .227 .252

DOB: March 22, 1987 OBP SLG OPS .351 .440 .791 .383 .543 .925 .308 .462 .771 .336 .461 .797

As a rookie in 2010, Davis ranked second on the Mets in home runs, doubles, and RBIs.21 He also ranked third on the Club for games played, and fifth in runs scored, OWAR, hits, OPS, SLG, and OBP.22 Similar to his 2012 season, Davis led all Mets players who played more than 75 games in fielding percentage with a .993 fielding percentage.23 His nine errors were also good for fifth fewest among NL first basemen in 2010.24 Davis continued the success of his rookie campaign prior to suffering a season ending injury (see Section V below) only 36 games into his sophomore campaign. However, Davis still managed to hit 7 home runs, good for fifth on the team for the entire season, with a batting average of .302 in those 36 games for the 2011 season. He also drove in 25 runs and scored 20 more in his shortened season. The numbers Davis registered in this short time span indicate that a very high-quality season was on the horizon, picking up right where he left off from his rookie year.                                                                                                                 19

Future Big League Stars highlight All-Rookie Team, Baseball America, http://www.baseballamerica.com/today/majors/awards/rookie-of-the-year/2010/2610794.html; Baseball Awards Voting for 2010, Baseball-Reference, http://www.baseball-reference.com/awards/awards_2010.shtml. 20 Ike Davis Statistics and History, Baseball-Reference, http://www.baseballreference.com/players/d/davisik02.shtml#contracts. 21 New York Mets Batting Stats – 2010, ESPN, http://espn.go.com/mlb/team/stats/batting/_/name/nym/year/2010/new-york-mets. 22 Id. 23 New York Mets Fielding Stats – 2010, ESPN, http://espn.go.com/mlb/team/stats/fielding/_/name/nym/year/2010/seasontype/2/new-york-mets. 24 Ike Davis Statistics and History, Baseball-Reference, http://www.baseballreference.com/players/d/davisik02.shtml#contracts.

 

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Davis returned from injury for the 2012 season to perform at a level consistent with his prior experience. In both of his two seasons playing more than 140 games, Davis ranked in the top two for the Mets in home runs and RBIs, and in the top three for doubles and walks.25 He also was in the top five for the Club in hits, SLG, runs, OPS, and OWAR.26 IV.

Comparative Baseball Salaries Ike Davis’s most recent season and overall career demonstrate his offense prowess and

defensive abilities. An additional tool to help measure Davis’s success and value is to compare him to similarly situated players. The following three players all represent first-time arbitration eligible players comparable to Davis. Mike Jacobs and Casey Kotchman both had just over three years of experience as first base, while Ryan Roberts, like Davis, was a “Super Two” corner infielder. Table 3, on the following page, illustrates the comparisons.

                                                                                                                25

New York Mets Batting Stats – 2010, ESPN, http://espn.go.com/mlb/team/stats/batting/_/name/nym/year/2010/new-york-mets. 26 Id.

 

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TABLE 3: Comparative Players Ike Davis (1B)27 MLB Service Time: 2.168 Salary Midpoint: $2,700,000 G R H 2B HR RBI BB 2012 156 66 118 26 32 90 61 Career 339 159 295 67 58 186 150 Mike Jacobs (1B)28 MLB Service Time: 3.047 Salary Midpoint: $3,275,000 G R H 2B HR RBI BB 2008 141 67 118 27 32 93 36 Career 569 248 493 116 100 312 170 Casey Kotchman (1B)29 MLB Service Time: 3.144 Salary Midpoint: $2,862,500 G R H 2B HR RBI BB 2008 143 65 143 28 14 74 36 Career 933 322 799 157 71 387 266 Ryan Roberts (3B)30 MLB Service Time: 2.150 Salary Midpoint: $1,962,500 G R H 2B HR RBI BB 2011 143 86 120 25 19 65 66 Career 450 189 323 65 41 152 152

Salary Request: $3,000,000 BA OBP SLG OPS .227 .308 .462 .771 .252 .336 .461 .797 Awarded Salary: $3,275,000 BA OBP SLG OPS .247 .299 .514 .813 .253 .313 .473 .786 Awarded Salary: $2,885,000 BA OBP SLG OPS .272 .328 .410 .738 .262 .328 .388 .715 Awarded Salary: $2,012,500 BA OBP SLG OPS .249 .341 .427 .768 .245 .324 .393 .717

Mike Jacobs earned a $3,275,000 salary, slightly above Davis’ requested amount, following a breakout season with the former Florida, current Miami, Marlins. Davis and Jacobs both hit 32 home runs and had 118 hits. Additionally, Jacobs and Davis posted vary similar numbers in other areas with Jacobs scoring 67 runs and Davis scoring 66, Jacobs having 93 RBIs and Davis having 90, and Jacobs hitting 27 doubles and Davis having 26. Defensively, Davis had a higher fielding percentage at .994, while Jacobs’ fielding percentage was .988. This comparison is indicative of the type of salary a player of Davis’ quality, combined with the performance Davis put forth in his most recent season, should earn.                                                                                                                 27

Ike Davis Statistics and History, Baseball-Reference, http://www.baseballreference.com/players/d/davisik02.shtml#contracts. 28 Mike Jacobs Statistics and History, Baseball-Reference, http://www.baseballreference.com/players/j/jacobmi02.shtml. 29 Casey Kotchman Statistics and History, Baseball-Reference, http://www.baseballreference.com/players/k/kotchca01.shtml. 30 Ryan Roberts Statistics and History, Baseball-Reference, http://www.baseballreference.com/players/r/roberry01.shtml.

 

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In addition to Jacobs, Casey Kotchman provides a nice comparison to Davis’ situation. After playing for the Los Angeles Angels of Anaheim and the Atlanta Braves during his third season of service, Kotchman was awarded a salary above his arbitration midpoint of $2,862,500 when he received $2,885,000 for the 2009 season. Although Kotchman hit for a better batting average and had 25 more hits and two more doubles in 2008 than Davis did in 2012, Davis notched 18 more home runs and 16 more RBIs than Kotchman. Davis also had a significantly higher OWAR at 1.0 compared to Kotchman’s -0.8.31 Kotchman’s salary award indicates that Davis should receive above the $2,700,000 midpoint established by the Mets offer and Davis’s request. Finally, Ryan Roberts represents an example of another “Super Two” player. Roberts’ situation is slightly different than Davis, however, as Roberts plays third base. Despite this, he is a good example of the end result in a “Super Two” arbitration proceeding resulting in a salary above the salary midpoint. Roberts and Davis compare very well in hits and doubles as Roberts had 120 hits to Davis’ 118 and Davis had 26 doubles to Roberts’ 25. While Roberts hit for a better average, .249 compared to .227. and had 20 more runs scored than Davis, Davis more than makes up for this disparity by hitting 13 more home runs and having 25 more RBIs than Roberts. The examples of Jacobs and Kotchman demonstrate that Davis’ request of $3,000,000 is reasonable and reflective of what first basemen of Davis’ caliber should earn. Roberts represents a situation where a “Super Two” received remuneration above the salary midpoint of his arbitration negotiation. Davis is similar to Roberts in that he respectfully believes he is entitled to a salary figure above the midpoint between the Club’s offer and his own request. All three of

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Ike Davis, Baseball Prospectus, http://www.baseballprospectus.com/card/card.php?id=DAVIS19870322A; Casey Kotchman, Baseball Prospectus, http://www.baseballprospectus.com/card/card.php?id=31601.

 

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these players’ salary arbitration situations show that Davis deserves a salary above the $2,700,000 midpoint. V.

Existence of Physical or Mental Defects Ike Davis sustained one main injury in his time at the major league level. In his second

season, he missed 126 games with a left ankle injury. Despite this, the Mets agreed to increase his salary for the successive season to the injury. In the 2012 season, the year after the injury, Davis showed no ill effects of the ankle injury. For the season after his ankle injury, Davis missed three days of training camp due to the valley fever illness and only one regular season game in June due to illness. Davis was tied for the Club lead in games played the year following his surgery with 156 appearances.32 VI.

Recent Performance of the Club In 2012, the Mets went 74 and 88, finishing 24 games behind the division winner and 14

games out of the wild card.33 Offensively, the Mets ranked in the bottom third of the league in offensive production, finishing 25th in runs scored and 22nd in home runs.34 Despite this overall team performance, Davis accounted for over 23% of the Mets home runs, 14.4% of the team’s RBIs, and over 10% of the Club’s runs scored. Davis’ offensive performance was extremely important to helping the Mets offense not finish even lower in the League rankings. VII.

Past Compensation Davis has received close to the league minimum in each of his years in the major league.

He received $506,690 for the 2012 season. This winter is his first arbitration eligible off-season due to his qualification as a “Super Two.” Davis has proven himself to be a reliable and                                                                                                                 32

Ike Davis Statistics and History, Baseball-Reference, http://www.baseballreference.com/players/d/davisik02.shtml#contracts. 33 2012 Regular Season Standings, ESPN, http://espn.go.com/mlb/standings. 34 MLB Team Stats – 2012, ESPN, http://espn.go.com/mlb/stats/team/_/stat/batting/year/2012/seasontype/2.

 

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consistent performer at first base for the Mets demonstrating that he should receive a salary appropriate for someone of his skill and performance. Table 4: Ike Davis (1B) Salary35 Salary 2011 $432,000 2012 $506,690

League Minimum $414,500 $480,000

VIII. Conclusion Davis has demonstrated that he can perform at a consistent level over the course of his career. His numbers prior to 2012 indicate that his most recent season’s success was no aberration and that his impressive performance will continue into the future. Further, Davis has shown that he is an integral part of the Mets offense and defense throughout his time with the Club. For the foregoing evidence presented in this brief and in oral argument, Ike Davis respectfully requests that this panel grants his request for a $3,000,000 salary for the 2013 season.

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Ike Davis, Baseball Prospectus, http://www.baseballprospectus.com/card/card.php?id=DAVIS19870322A.

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