IN THE MATTER OF A SALARY ARBITRATION
BETWEEN:
CHRIS STEWART
-AND-
THE ST. LOUIS BLUES
BEFORE: NATIONAL ACADEMY OF ARBITRATORS
BRIEF IN SUPPORT OF A COMPENSATION REQUEST FOR CHRIS STEWART
Team 15, Counsel and Agent
TABLE OF CONTENTS
I. INTRODUCTION…………………………………………………….…....…………1
II. OVERVIEW PERFORMANCE OF THE PLAYER……………………….……...... 2
III. NUMBER OF GAMES PLAYED AND INJURY HISTORY………….……….…...2
IV. CAREER-TO-PLATFORM STATISTICS …………………....…….………....….. 3
V. PLATFORM-STATISTICS……………………………………....…………………...3
VI. OVERALL CONTRIBUTION TO THE CLUB………………………...……………4
VII. COMPARABLE PLAYERS………………………………………………..………...5
a. Mr. Stewart compared to Mr. Versteeg …………………………………………..6
b. Mr. Stewart compared to Mr. Wheeler …………………………………………...7
VIII. CONCLUSION……………………………………………………………..…………8
I. INTRODUCTION
This brief will provide admissible evidence pursuant to the terms of the Collective
Bargaining Agreement (“CBA”),1 between the National Hockey League (“NHL”) and the
National Hockey League Players Association (“NHLPA”), to assist in quantifying Chris
Stewart’s (“Mr. Stewart” or “the Player”) monetary value to the St. Louis Blues (“the Blues” or
“the Club”) for the 2013-2014 NHL season.
It is recognized that Mr. Stewart is eligible for salary arbitration to determine his compensation with respect to the 2013-2014 season. To that end, the Player has exercised this option and can only be compared to forwards with the same arbitration rights.
This brief will provide a framework that is capable of awarding appropriate value to Mr.
Stewart’s offensive contributions to the Blues. In awarding value to a forward, such as Mr.
Stewart, NHL experience and points per game (“Pts/G) carry the most weight in appreciating a player’s worth to their Club. In this context, Mr. Stewart’s valuation will consider: overall performance, number of games played, injury history, length of service, and his overall contributions to the Blues. Mr. Stewart will also be objectively compared against two additional forwards by specified statistical filters with respect to their career-to-platform and platform- seasons in order to validate his positioning in the NHL marketplace. The salaries of the comparable forwards will frame the narrow range to assign Mr. Stewart’s value.
On behalf of the Player, Mr. Stewart, we respectfully submit that $4,500,000 is an accurate and equitable assessment of his value to the Blues for the 2013-2014 season.
1 NHL Collective Bargaining Agreement, between the National Hockey League and the National Hockey League Players Association, September 16, 2012- September 15, 2022, s. 12.1(a)-(c), p 57.
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II. OVERVIEW ASSESSMENT OF THE PLAYER
Mr. Stewart is a 25 year-old, right-handed player from Toronto, Ontario who will turn 26 in October 2013. Mr. Stewart is 6’2”, 231lbs., as of the beginning of the 2012-2013 NHL season.
In the 2006 NHL Entry Draft (“Entry Draft”) the Colorado Avalanche (“the Avalanche”) selected Mr. Stewart, in the first round, 18th overall.2 The Player’s high selection in the Entry
Draft is the partial result of the high value teams place on his style of play.
Mr. Stewart is one of the purest power forwards in the NHL with a rare combination of power, size and skill that allows him to consistently create scoring situations. Mr. Stewart remained with the Avalanche until February 19th, 2011 when the Blues acquired him via a player transaction.3
Aside from his NHL experience, Mr. Stewart was selected to represent Team Canada at the World Hockey Championships after the 2010-2011 NHL season. Mr. Stewart scored 2 goals and 2 assists in the 7 games in which he played.4
III. NUMBER OF GAMES PLAYED AND INJURY HISTORY
Mr. Stewart has played five seasons in the NHL accumulating 319 games, 154 of which were with the Blues.5 During the 2008-2009 season, Mr. Stewart split his playing time between the Avalanche and their American Hockey League (“AHL”) affiliate.
During the 2010-2011 regular season, Mr. Stewart suffered a broken left hand and was forced to miss 21 games.6 Mr. Stewart has since played in all games over the past two seasons, with the exception of a three game suspension for a hit from behind in 2011-2012. It is the
2 The Sports Network online:
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Player’s submission that playing on a consistent basis increases the Player’s worth to a team.
This offers the Blues an offensive pillar in their lineup on consistent basis and lends itself to the longevity of a player’s career.
IV. CAREER-TO-PLATFORM STATISTICS
Table 1: Mr. Stewart’s Career Performance7 Season Team GP G A P TOI PIM PPG GWG S S% Hits 08-09 Avalanche 53 11 8 19 12:19 54 1 1 98 11.2 80 09-10 Avalanche 77 28 36 64 16:41 73 3 5 221 12.7 100 10-11 Avalanche 36 13 17 30 17:29 38 5 3 95 13.7 56 10-11 Blues 26 15 8 23 15 7 2 67 22.4 11-12 Blues 79 15 15 30 15:26 109 2 1 166 9.0 112 12-13 Blues 48 18 18 36 15:49 40 6 3 97 18.6 41 NHL Totals 319 100 102 202 15:33 329 24 15 744 13.4 389 * Red font in Table indicates platform season.
Mr. Stewart’s comprehensive analysis will use both, career-to-platform statistics and his platform-season statistics to determine the most appropriate positioning for Mr. Stewart in the current marketplace. Mr. Stewart has recorded career highs in his 2009-2010 platform-season with 28 goals, 36 assists for a total of 64 points, which equates to 0.83 Pts/G in 77 games played.8 While he failed to surpass this performance since 2009-2010, he has remained consistent by matching his 28 goals in the subsequent season between the Avalanche and the
Blues. 9
Mr. Stewart’s career scoring statistics suggest that he is a proven and balanced point producer. The theme of offensive consistency is apparent throughout his career and little weight should be placed on the outlying 2011-2012 season (see Table 2). Moreover, Mr. Stewart’s career-to-platform statistics speak to the reliability of his statistical pace during his platform- season.
7 Supra note 4. 8 Ibid. 9 Ibid.
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V. PATFORM-SEASON STATISTICS
Mr. Stewart played 48 games in his platform-season, which is a sufficient sample to gauge his contributions to the Blues and to determine an appropriate salary. Mr. Stewart was on pace to surpass his career highs in goals per game (0.38), points per game (0.75) and S% (18.6) during the current platform season however he was restricted by the shortened lockout schedule.10 Mr. Stewart’s career-to-platform statistics support the possibility of an increase in
Pts/G totals in this platform-season. To that end, Mr. Stewart’s platform-season can be relied upon to measure the valuable impact his offence has on the Blues’ success.
VI. OVERALL CONTRIBUTION TO THE CLUB
The Blues began the 2012-2013 season with a 10-7-2 record. Mr. Stewart’s ice-time increased steadily over each month of the season, which demonstrates that Mr. Stewart was entrusted with ice time in crucial situations of the game.11 Mr. Stewart accounted for 23pts
(0.79Pts/G) in the final two months of the season during a 19-10 record to complete the season and clinch 4th place in the Western conference. Of the team leading 18 goals Mr. Stewart scored in this platform-season, 11 of them were scored to break a tie in the game.12 Accordingly, it should be acknowledged that Mr. Stewart had 8 more points then the second leading point producer on the Blues last season, despite six forwards averaging more TOI per game than him.
It is highly valuable when a player is able to create and maintain offence against top defensive competition, as revealed by his Relative Corsi quality of competition of 0.672 and an offensive zone finish of 51.2%.13 The Blues rely upon Mr. Stewart for his offensive talents but also for his physical play. Mr. Stewart was the only player in top 50 NHL scorers who registered 4 fighting
10 Ibid. 11 NHL.com, Statistics: http://www.nhl.com/ice/player.htm?id=8473485&view=splits 12 Ibid. 13 Behind the Net Hockey Analysis and Statistics online:
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majors.14 Due to Mr. Stewart’s impact on to the Blues success, he should be compensated accordingly.
VII. COMPARABLE PLAYERS
The Player’s positioning in the NHL marketplace is the most influential factor when assigning their value to a Club. Thus, the search for and selection of comparable players to determine a players positioning in the NHL marketplace is the most pivotal stage in the salary arbitration process. In order to arrive at the group of players who best compare to the Player in question an objective statistical criteria must be employed.
Mr. Stewart is an elite power forward in the NHL who consistently creates scoring opportunities for himself and his teammates through his skill and size. The selection of objective search filters allows for a more comprehensive comparison of a forward’s offensive characteristics. The objective filters that we employed are based both on, career-to-platform statistics and platform-season statistics which are as follows: games played (“GP”) +/- 25%, goals per game (“G/G”) +/-15%, points per game (“Pts/G”) +/-20%, shooting percentage (“S%”)
+/-30%, and time-on-ice (“TOI”) +/- 5:00/G.
Table 2: Statistics for Comparable Players15 Player GP G G/G A Pts Pts/G TOI/G Hits S% GWG Chris Stewart 48 18 0.38 18 36 0.75 15:49 41 18.6 3 NHL Totals: 319 100 0.31 102 202 0.63 15:33 389 13.4 15 Blake Wheeler 48 19 0.4 22 41 0.85 18:48 90 14.7 2 NHL Totals: 372 93 0.25 139 232 0.62 16:51 396 11.3 12 Kris Versteeg 71 23 0.32 31 54 0.76 19:54 52 12.7 5 NHL Totals: 321 88 0.27 113 201 0.63 17:38 190 12.5 12
14 NHL.com, Statistics: http://www.nhl.com/ice/playerstats.htm?season=20122013&gameType=2&team=&position=S&country=&status=& viewName=summary 15 Supra note 2; see also Blake Wheeler and Kris Versteeg.
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Table 3: Contract Data16 Player 2013-2014 Cap Hit Date Signed Blake Wheeler $5,600,000 July 26, 2013 Chris Stewart $4,500,000 Pending Arbitration Kris Versteeg $4,400,000 July 23, 2012
a. Mr. Stewart compared to Mr. Versteeg
Kris Versteeg (“Mr. Versteeg”) is a 27 year-old right-handed winger from Lethbridge,
Canada that was drafted in the 5th round, 134th overall in the 2004 Entry Draft by the Boston
Bruins. Mr. Versteeg played five seasons with three other teams before being acquired by the
Florida Panthers.17 Mr. Versteeg’s statistics are prorated to the 2011-2012 totals to best represent the value of his contributions in the 2011-2012 marketplace when he signed his contract.
Mr. Stewart has comparable NHL experience to that of Mr. Versteeg. Despite Mr.
Versteeg playing more games within his respective platform-seasons, Mr. Stewart has slightly more goals per game and a more favourable shooting percentage over his career and in his platform-season (see table 2). Mr. Stewart and Mr. Versteeg have in effect the same amount of
Pts/G in their platform-season and over the career-to-platform seasons, despite Mr. Stewart playing four minutes less per game.18 However, ice time is awarded at the coach’s discretion and is based on the depth of that position for the specific team. Little weight should therefore be placed on a forward’s TOI to determine the value.
It should be noted that Mr. Versteeg’s current salary was awarded on an identical Pts/G increase during his platform-seasons as compared to his career-to-platform statistics. This should serve as model of how to appropriately compensate Mr. Stewart for his increased Pts/G in the
2013-2014 platform season.
16 Capgeek online: http://capgeek.com/player/247. 17 TSN.ca, Statisitics: http://www.tsn.ca/nhl/teams/players/bio/?id=4566 18 Ibid..
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Mr. Stewart and Mr. Versteeg are comparable players in terms of statistical contributions, style-of-play, and length of service. In consideration of these similarities, Mr. Versteeg represents an appropriate marker for which Mr. Stewart’s value should not drop below. It is the
Player’s position that his added physical play should distinguish Mr. Versteeg’s value in favour of Mr. Stewart. Therefore, Mr. Stewart should be compensated at a slightly higher rate than that of Mr. Versteeg.
b. Mr. Stewart compared to Mr. Wheeler
Blake Wheeler (“Mr. Wheeler”) and Mr. Stewart are the most appropriate comparables in terms of their contributions to their Clubs, during their platform-seasons and throughout their career-to-platform performances. Mr. Wheeler is a 27 year-old, right-handed winger from
Robbinsdle, United States. Similar to Mr. Stewart, Mr. Wheeler was drafted in the 1st round 5th overall although in the 2004 Entry Draft by the Phoenix Coyotes.19 Mr. Wheeler was subsequently signed by the Bruins as a free agent and then traded to the Winnipeg Jets, formerly known as the Atlanta Thrashers during the 2010-2011 season.20 After the 2010-2011 season, Mr.
Wheeler, like Mr. Stewart, represented his country at the World Hockey Championships, where only one assist separated the two players in favor of Mr. Wheeler over the 7 games played. 21
In his platform season, Mr. Wheeler recorded 0.4 G/G and 22 assists that amounted to
0.85 Pts/G in 48 games played. In comparison, Mr. Stewart had recorded slightly less by scoring
0.38 Pts/G and 18 assists for 0.75 Pts/G over 48 games played (see table). Interesting to note, both players are able to create offence on their own as demonstrated by an 8 point differential between themselves and the next closest point producer on their team.22
19 Supra Note 4; See also Blake Wheeler. 20 Supra Note 2: See also Blake Wheeler. 21 Ibid. 22 NHL.com; See Also Winnipeg Jets.
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During Mr. Wheeler’s career, in 372 games played, he has scored an average of 0.25 G/G and 0.62 Pts/G. Mr. Stewart, in 319 career games, has recorded an average of 0.31 goals per game and 0.63 points per game (see table). Mr. Stewart has managed to maintain this offensive production; with a higher goal scoring, points average, and shooting percentage than Mr.
Wheeler during his career, despite averaging less time-on-ice than Mr. Wheeler. Given their similarities, Mr. Wheeler is the most appropriate comparable player, and thus, Mr. Stewart deserves a salary in the narrow range of Mr. Wheeler’s salary.
VIII. CONCLUSION
This brief has assessed Mr. Stewart’s value with respect to his overall career performance, NHL experience and injury history, his overall contributions to the Club, and identified two comparable players to best frame the current market value. The head-to-head comparisons demonstrate the appropriate selection of comparable players, which frame the current market value for Mr. Stewart. Mr. Stewart should be awarded $4,500,000. In consideration of the totality of Mr. Stewart’s contributions leading up to this arbitration, it is respectfully submitted that the compensations request of 4,5000,000 be granted for being an accurate assessment of what Mr. Stewart is worth for the 2013-2014 season.
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