T

Michael Goldberg 2L

EASL

735 Longacre Ave

Woodmere NY,11598

(516) 369-3167

MichaelGoldberg21@Gmail.com
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Introduction and request for hearing decision

This brief, submitted on behalf of the Atlanta Braves Baseball Club (“Braves”), will analyze the

statistical production, attributes, team attributes, awards, player salaries, and personal physical condition of the

playing career of Jair Jurrjens (“Mr. Jurrjens”), currently a starting pitcher (“SP”) for the Atlanta Braves. This

arbitration will consider the criteria of The Major League Baseball (“MLB”) Collective Bargaining Agreement

(“CBA”) between the MLB clubs and the MLB Player’s Association. According to the CBA, the following

components of Mr. Jurrjens’ playing career are to be considered: 1) Mr. Jurrjens’ contribution to the club

during the past season, including his overall performance, leadership qualities, and special public appeal; 2) the

length and consistency of his playing career; 3) his past recorded compensation amounts; 4) comparative

baseball salaries of other similar players; 5) the existence of any mental or physical defects on the part of Mr.

Jurrjens; and 6) the recent performance of the Braves, including, but not limited to, the team’s league standing

and attendance as an indication of public support and interest in the team.1 In examining the comparable

salaries of other major league players, particular attention will be leant to players whose MLB service is no

greater than one year above Mr. Jurrjens’ current annual service group.2 Moreover, a comparative analysis of

players who similarly became arbitration eligible for the first time prior to the 2010, will serve as comparative

1
MLB Collective Bargaining Agreement, “2007-2011 Basic Agreement”, Article
VI(F)§12(a)-(b). pp 18-19, available at http://mlbplayers.mlb.com/pa/pdf/cba_english.pdf.
2
Id.
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data for Mr. Jurrjens’ case, as they are not only the most recent results, but reflect the current market for MLB

salaries.

The financial position of the Braves organization, press comments and material on Mr. Jurrjens’ or the

Braves’ performance, as well as offers made by either party prior to the arbitration process, shall not be

considered as evidence in this arbitration proceeding.3 Currently, Mr. Jurrjens has 3.047 years of Major League

service time and is arbitration eligible for the first time this offseason. The Braves respectfully request that the

arbitration panel consider the analysis contained in this document, as well as the argument presented at the oral

hearing, and find that Mr. Jurrjens is entitled to receive a 2011 salary arbitration award of $3.4 million,

equivalent to the club’s final offer.

Quality of Player’s Contribution During Past Season

2010 was a disappointing season for Mr. Jurrjens, as he battled injuries all season leading to missed

games, and poor performance when he did pitch. His ailments began in spring training, as he needed an MRI

for his pitching shoulder, and continued to play despite an early hamstring injury.4 He missed the entire month

of May, all but one game in June, and only made three starts in September, due to a torn meniscus in his knee.5

He battled arm and shoulder problems early in the season and continued to suffer knee injuries later in the

season, which resulted in arthroscopic knee surgery after the season.6 The following table details Mr. Jurrjens’

contributions during the 2010 season.

Table 17

3
Id.
4
http://www.baseballinjurytool.com/playerresult.php?eliasID=457453
5
http://mlb.mlb.com/stats/individual_player_gamebygamelog.jsp?
c_id=atl&playerID=457453&statType=2
6
http://sports.espn.go.com/mlb/news/story?id=5708617
7
http://mlb.mlb.com/team/player.jsp?player_id=457453
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W L ERA G GS CG SHO IP H R ER HR HB BB SO AVG WHIP GO/AO
7 6 4.64 2 20 0 0 116. 12 6 60 13 2 42 86 .270 1.39 1.02

0 1 0 3

As a result of injuries, Mr. Jurrjens was only able to amass 116.1 innings pitched (“IP”). He was tied for

4th on the team in wins, 13th in earned run average (“ERA), and 12th in walks and hits per inning pitched

(“WHIP”).8 This marked a sharp decline from his 2009 season, when he finished the season with a 14-10

record, along with a 2.60 ERA and a 1.21 WHIP.9 The Braves were counting on Jurrjens to be a top of the

rotation starter, yet his performance was far from that. He gave up more hits than innings pitched, struck out

just 6.65 batters per 9 innings (“K/9”), and gave up 3.25 walks per 9 innings (“BB/9), equaling a pedestrian

2.05 strikeout to walk ratio (“K/BB”).10 When a pitcher puts so many players on base like Mr. Jurrjens did in

2010, it is hard to be successful especially if you do not strike batters out. Mr. Jurrjens ranked 91st in the league

in K/9 and sported a high WHIP, so it is not surprising to see an ERA of 4.64.11

There are two final stats to look at when analyzing Mr. Jurrjens’ performance. The first is win

advancement (“+WPA”), which is the amount of positive wins a player contributed to his team, including only

the plays where he increased his team’s win expectancy.12 The second is loss advancement (“-WPA”), or the

amount of negative wins a player contributed to his team, including only the plays where he decreased his

team’s win expectancy.13 Mr. Jurrjens had a +WPA of 9.53 and a –WPA of -10.48.14 Taking into account only
8
http://atlanta.braves.mlb.com/stats/sortable_player_stats.jsp?
c_id=atl&baseballScope=BS1&teamPosCode=all&statType=2&timeSubFrame=2010&sit
Split=&venueID=&Submit=Submit&timeFrame=1
9
http://mlb.mlb.com/team/player.jsp?player_id=457453
10
http://www.fangraphs.com/statss.aspx?playerid=5556&position=P

http://www.fangraphs.com/leaders.aspx?
11

pos=all&stats=pit&lg=all&qual=y&type=8&season=2010&month=0
12
http://www.fangraphs.com/blogs/index.php/glossary/
13
Id.
14
http://www.fangraphs.com/statss.aspx?playerid=5556&position=P
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his overall performance, this means he cost his team .95 wins in 2010. Other pitchers who cost their team fewer

games in comparable innings pitched include: Jeff Karstens of the Pittsburgh Pirates, Jenmar Gomez of the

Cleveland Indians, and Aaron Cook of the Colorado Rockies.15 Ultimately, it may have been a blessing that he

only pitched 116.1 innings.

Length and Consistency of Career Contributions

Although Mr. Jurrjens experienced some success in 2008 and 2009, in 2007 and 2010, he failed to demonstrate

consistent success through his major league career. The following table displays his career numbers:

Table 216

Mr. Jurrjens was called up from the minor leagues by the Detroit Tigers in 2007, yet his performance

was unimpressive.17 He posted a 3-1 record, with a 4.70 era and a 1.14 whip. He had a K/9 of just 3.82, a 3.23

BB/9, and a meager 1.18 K/BB. His average IP per start was an abysmal 4.3.18 This makes it very hard to win

games when you need 5IP to qualify for a win.19 Mr. Jurrjens was extremely fortunate that his batting average

on balls in play (“BABIP”) was just .214.20 There are stats that take into account fielding independent pitching

(“FIP”), the most useful being XFIP (“expected fielding independent pitching”).21 XFIP considers all elements

http://www.fangraphs.com/leaders.aspx?
15

pos=all&stats=pit&lg=all&qual=y&type=8&season=2010&month=0
16
http://sports.yahoo.com/mlb/players/8091/career;_ylt=Av6AvzPlZICC_kblW9KTzgGFCLc
F
17
Id.
18
http://www.fangraphs.com/statss.aspx?playerid=5556&position=P
19
http://mlb.mlb.com/mlb/official_info/official_rules/official_scorer_10.jsp
20
http://www.fangraphs.com/statss.aspx?playerid=5556&position=P
21
http://saberlibrary.com/pitching/xfip/
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under the pitchers control (Ks, BBs, GB/FB ratio) and eliminates the factors that are out of their control

(BABIP, and whether an outfield fly ball is a Homerun or not).22 Accordingly, this stat adjusts a pitcher’s era

for better or worse, based on how lucky he was, and has the highest correlation with future ERA of all pitching

metrics.23 Mr. Jurrjens’ XFIP in 2007 was 5.48, which means that his unimpressive 4.70 era should have even

worse.24

In 2008, Mr. Jurrjens put together his first impressive season, posting a 13-10 record with a 3.68 era and

a 1.37 whip while pitching 188.1 innings.25 He improved his innings pitched per start to 6.1, as well as his K/9

to 6.64.26 However, his BB/9 climbed to 3.35 and his XFIP was 3.96, which again demonstrates that his

successes may have been a result of good luck.27

In 2009, Mr. Jurrjens delivered his best season, or so his numbers would lead you to believe. He went

14-10 with a 2.60 era and a 1.21 whip.28 He pitched 215 innings, raising his IP per start to 6.3 and lowering his

BB/9 to 3.14.29 However, his K/9 dropped to 6.36 and he was extremely fortunate with his BABIP (.273) as he

left a whopping 79.4% men on base (“LOB%”).30 While at first glance his numbers in 2009 look like top of the

rotation material, a closer look shows that again, Jurrjens’ success was mainly owing to good luck. His XFIP

was 4.34 almost an entire 2 runs higher than his actual era.31 Furthermore, his 215IP were a big jump from the

previous years 188.1. This increase in workload likely led to the shoulder inflammation he suffered prior to the

2010 season.
22
Id.
23
Id.
24
http://www.fangraphs.com/statss.aspx?playerid=5556&position=P
25
http://mlb.mlb.com/team/player.jsp?player_id=457453
26
http://www.fangraphs.com/statss.aspx?playerid=5556&position=P
27
Id.
28
http://mlb.mlb.com/team/player.jsp?player_id=457453
29
http://www.fangraphs.com/statss.aspx?playerid=5556&position=P
30
Id.
31
Id.
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Mr. Jurrjens had troubling trends from 2008 to 2009, despite the decrease in ERA. He stopped inducing

ground balls at a rapid rate as his groundball percentage (“GB%”) dropped from 51.5 to 42.1, and his

groundball to fly ball ratio (“GB/FB”) normalized from 1.94, to a league average 1.10.32 Furthermore, his fly

ball rate (“FB%”) rose from 26.5 in ‘08 to 39.1 in ‘09 to 41.9 in 2010.33 His LOB% also rose dramatically from

71%, which is roughly the league average, to an unheard of 79.4%, well above the league average.34 Lastly, his

BABIP, which stood at .311 in ‘08, dropped to .273 in ’09.35 A comparison of his 2009 and 2010 performance

indicates that Jurrjens consistently delivered a poor performance, but had vastly different results, simply

inflated by lady luck. These tables will compare the production.

Table 336:
200 6.36 K/9 3.14 BB/9 2.03 K/BB

201 6.65 k/9 3.25 BB/9 2.05 K/BB Table 4 37:

0
200 .63 Homeruns per 9 ip (“HR/9”) 1.10 GB/FB .273 BABIP 79.4 LOB%
9

201 1.01 HR/9 .95 GB/FB .301 BABIP 69.3 LOB%

0

Table 3 shows in 2009 and 2010, Mr. Jurrjens had nearly identical statistics in the categories that

pitchers control. However, Table 4 shows why his ERA went from 2.60 to 4.64. His stats normalized and

showed the type of pitcher he really is. Mr. Jurrjens is a pitcher with a low K/9 mark, a pedestrian K/BB ratio,

and a barely average GB/FB. This makes his 2009 seem like a statistical aberration.

32
Id.
33
Id.
34
Id.
35
Id.
36
Id.
37
Id.
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Past Player Compensation

Mr. Jurrjens has 3.047 years of Major League service under his belt, and is arbitration eligible for the

first time.38 The Detroit Tigers signed him as an undrafted free agent in 2003, and he made his Major League

debut on Aug. 15, 2007.39 Mr. Jurrjens received $390,000 in 2008, $450,000 in 2009, and $480,000 in 2010.40

Under the CBA, a player does not become arbitration eligible until he has reached 3 years of Major

League service, or has achieved “Super Two” status.41 Mr. Jurrjens qualifies for arbitration for the first time,

and has many question marks regarding his performance and health. He missed a substantial amount of playing

time in 2010, has been extremely inconsistent with his pitching on a year to year basis, had many injuries in the

past, and recently underwent surgery to repair his torn meniscus, an injury that is likely a recurring one. Due to

these question marks, Mr. Jurrjens should be rewarded a total of $3.4 million in arbitration.

Comparative Baseball Salaries

According to the CBA, the arbitration panel may consider the salaries of comparable players and give

specific attention to contracts of players with Major League service not exceeding one annual service group

above Mr. Jurrjens’.42 This section will compare Mr. Jurrjens value against that of Chad Billingsley, SP for the

Los Angeles Dodgers, and John Danks, SP for the Chicago White Sox. Each of these players was arbitration

eligible for the first time prior to the 2010 season. The contracts they received will be used to establish that Mr.

Jurrjens should receive $3.4 million in arbitration. The following table compares the respective careers of Mr.

Jurrjens, Mr. Billingsley, and Mr. Danks:

38
http://www.baseball-reference.com/players/j/jurrjja01.shtml
39
Id.
40
Cot’s Baseball Contracts: http://mlbcontracts.blogspot.com/2005/01/atlanta-
braves_15.html

MLB Collective Bargaining Agreement, “2007-2011 Basic Agreement”, Article

41

VI(F)§12(a)-(b). pp 18-19
42
Id.
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Player Platform Year Comparison-Table 543

Pitcher D.O.B Experience G GS IP W L H SO BB ERA WHIP K/9

Jurrjens(2010) 1/29/86 3.047 2 20 116. 7 6 12 86 42 4.64 1.39 6.65

0 1 0

Billingsley(2009) 7/29/84 3.110 3 32 196. 1 1 17 17 86 4.03 1.32 8.14

3 1 2 1 3 9

Danks(2009) 4/15/85 3.000 3 32 200. 1 1 18 14 73 3.77 1.28 6.70

2 1 3 1 4 9

The 2009 season was used as the platform year to determine Mr. Billingsley’s and Mr. Dank’s salaries

for their arbitration eligible year. Mr. Jurrjens’ 2010 production will be used as his platform year to determine

what his salary should be for the upcoming 2011 season. Mr. Billingsley signed a 1 year $3.85 million dollar

deal following his platform year.44 He appeared in 13 more games, had 80 more IP, his ERA was .61 lower; his

whip was .07 better, and he had 1.49 more K/9 than Mr. Jurrjens. Considering Mr. Billingsley was healthy all

year and significantly out performed Mr. Jurrjens in every major pitching category, his contribution to his team

was much greater than that of Mr. Jurrjens’. Based on these evaluations, Mr. Jurrjens deserves to make

significantly less than Mr. Billingsley’s $3.85, which exemplifies why $3.4 million dollars is what he should

make. Further, the midpoint is $3.8 million, and according to the midpoint theory, if the arbitration panel finds

that the player is worth a penny less than the midpoint, the team wins.45 If Mr. Billingsley is worth $3.85

million, Mr. Jurrjens is certainly not worth $3.8 million.

Comparing Mr. Danks’ platform year to Mr. Jurrjens’ yields similar results. Mr. Danks signed a 1-year,

$3.45 million deal after his platform year.46 The statistics show that Mr. Danks was both healthier and more

productive than Mr. Jurrjens in every major statistical category. He appeared in 12 more games, had 84 more
43
http://mlb.mlb.com/stats/sortable_player_stats.jsp
44
http://mlbcontracts.blogspot.com/2001/10/2010-arbitration-eligibles.html
45
MLB Collective Bargaining Agreement, “2007-2011 Basic Agreement”, Article
VI(F)§12(a)-(b)p.14
46
http://mlbcontracts.blogspot.com/2001/10/2010-arbitration-eligibles.html
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IP, won almost double the amount of games, had a better K/9, his whip was .11 lower, and his ERA was a

whopping .87 runs lower than Mr. Jurrjens’. Mr. Danks outperformed Mr. Jurrjens significantly in his platform

year, making $3.45 million dollars. Therefore, due to the performance in his platform year, coupled with his

troublesome injury record, a $3.4 million award in arbitration given to Mr. Jurrjens would be a rather generous

offer.

Existing Physical or Mental Defects

Mr, Jurrjens has experienced a plethora of injuries and surgeries throughout his short Major League

career. Before the 2010 season started, he missed about a month of spring training due to shoulder

inflammation.47 On April 30, he was placed on the 15 day DL for a hamstring injury that kept him sidelined for

61 days.48 On top of all of this, he tore his meniscus in his knee on Sept.15, 2010, which led him to miss the rest

of the year.49

This injury-prone pattern was established even before Jurrjens Major League career, as he also suffered

injuries prior to the 2010 season. In 2008 he had blisters on his thumb and sprained his ankle, missing a total of

5 days. Additionally, in 2007, he went on the 15 day DL due to rotator cuff inflammation and missed 16 days.50

In total, Mr. Jurrjens has suffered 2 shoulder injuries, 1 knee injury, 1 thigh injury, 1 hand injury and 1

ankle injury. He has missed a total of 134 days in just 3 years.51 It seems he is headed down the road of a player

labeled “injury prone”. His most serious injury was the torn meniscus he suffered at the end of the year, and

although he underwent corrective surgery, it can often pose long-term consequences: The meniscus consists of

two fibro cartilage discs inside the knee joint. The discs provide cushion between the bones that form the joint,

47
http://www.baseballinjurytool.com/playerresult.php?eliasID=457453
48
http://www.baseballinjurytool.com/playerresult.php?eliasID=457453
49
Id.
50
Id.
51
Id.
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and they increase joint stability.52 The absence of a portion of the meniscus results in bone-on-bone contact,

which can lead to wearing of the protective cartilage and inflammation.53 Although he has received treatment

for his ailments, he may be at risk for further injury in the future. Considering Jurrjens’ injuries, both past and

present (and the potential aftermath of these ailments), Mr. Jurrjens is said to have existing physical defects.

Recent Performance of the Club

The Atlanta Braves finished the 2010 season with 91 wins and 71 losses, winning the National League

Wild Card.54 Due to his meniscus injury Mr. Jurrjens was absent as the Braves were contending down the

stretch. The Braves were defeated in the National League Divisional Series in 4 games, a series that Mr.

Jurrjens missed due to injury. The Braves made the post-season; however, this was without Mr. Jurrjens. If

anything, he hindered their overall performance. The Braves average home attendance in 2010 was 30,989

people, good for 13th in Major League Baseball.55 However, in games that Mr. Jurrjens started, that average

number dropped to 26,794, 4,195 people less than average.56 Therefore, Mr. Jurrjens should not be credited

with helping his team make the playoffs or boosting their attendance in 2010.

Conclusion

Mr. Jurrjens 2010 season was riddled with injuries and poor statistics. His performance was about the

same as 2009, when he had his breakout year, however, his luck finally ran out and his numbers normalized to

less than stellar. Mr Jurrjens’ XFIP in 2010 was 4.47 and he has a career XFIP of 4.30.57 Due to his lack of

production, substantial history of injuries, potential for future injuries, and in consideration of the criteria listed

in the CBA, the Atlanta Braves respectfully ask that the panel find that Mr. Jurrjens is due $3.4 million as an

arbitration award.

52
http://sports.espn.go.com/fantasy/baseball/flb/story?page=injury101
53
Id.
54
http://espn.go.com/mlb/standings
55
http://espn.go.com/mlb/attendance
56
http://sports.espn.go.com/mlb/players/gamelog?playerId=28854 (using attendance
figures from each game he pitched)
57
http://www.fangraphs.com/statss.aspx?playerid=5556&position=P
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