2013 HOCKEY ARBITRATION COMPETITION OF CANADA

Chris Stewart v St. Louis Blues (NHL)

SUBMISSION ON BEHALF OF CHRIS STEWART

TEAM #14

TABLE OF CONTENTS

PART I – INTRODUCTION AND REQUEST FOR HEARING ...... 1

PART II – ANALYSIS OF CHRIS STEWART ...... 1

PART III – SELECTION OF COMPARABLE PLAYERS ...... 3

PART IV – STEWART AND THE COMPARABLE PLAYERS ...... 5

A) ...... 6

B) ...... 7

PART V – CONCLUSION ...... 8

PART I – INTRODUCTION AND REQUEST FOR HEARING

This brief outlines the position of the Chris Stewart (“Stewart” or “the Player”) in this arbitration hearing with the St. Louis Blues Hockey Club (the “Club”) to determine

Stewart’s salary for the 2013-14 season. The framework for information that may be considered in this arbitration hearing is set out in Article 12.9, subsections (g)(ii) and (iii) of the 2013 Collective Bargaining Agreement (“CBA”) between the

(“NHL”) and the National Hockey League Player’s Association (“NHLPA”).

The reason for conducting this arbitration hearing is because the Club and Stewart have, to this point, been unable to negotiate an agreeable salary for the upcoming 2013-14 season. Based on the arguments contained in this brief, the Stewart and his representatives respectfully contend that he should be paid a salary of at least $1 above $4,150,000.

PART II – ANALYSIS OF CHRIS STEWART

Chris Stewart was born on October 30, 1987 in Toronto, , Canada.1 At the age of

25 on September 15th, Stewart became arbitration eligible at the conclusion of the shortened

2012-13 NHL season under section 10.2(a)(i)(A). He stands at 6’2” tall and weighs in at 231lbs.2

The Avalanche (“Avalanche”) selected him in the 1st round (18th overall) of the 2006

NHL entry draft.3

Stewart signed a three-year entry-level contract with the Avalanche in 2007 that paid him

$850,000 per year.4 He spent one full season with the Lake Erie Monsters of the American

Hockey League before making the jump to the NHL in the 2008-09 season. In 2009-10, Stewart

1 NHL Player Profile, http://www.nhl.com/ice/player.htm?id=8473485 2 Ibid. 3 Ibid. 4 Capgeek Player Contract History, http://capgeek.com/player/560

1 exploded onto the NHL scene registering 28 goals to go along with 64 points and 73 minutes in 77 games played.5 This performance vaulted Stewart into an elite group of dynamic power forwards who possess both an innate ability to score and an unyielding physical presence on the ice. He was rewarded after this breakout season with a new two-year contract paying him an average of $2,875,000 per year over that span.6

The following year Stewart began the season on another torrid pace and was leading the

Avalanche in scoring with 11 goals and 25 points through 23 games played before breaking his left hand in a fight with Kyle Brodziak of the Wild.7 Stewart returned to the ice after missing the next 21 games,8 the longest injury of his career, but struggled to regain his form as he posted 5 points over the next 13 games with the Avalanche.9 It was at this point the Club was acquired Stewart in a blockbuster with the Avalanche. The trade saw Stewart join the

Club along with defenceman Kevin Shattenkirk and a conditional 2nd round pick in exchange for defenceman Erik Johnson, the 1st overall pick of the 2006 NHL entry draft, forward Jay

McClement, and a conditional 1st round pick.10 Upon joining the Club, Stewart was able to find his game again and went on to finish the 2010-11 season with an impressive 15 goals, 23 points and 15 penalty minutes in 26 games with the Club.

Stewart’s offensive production during the 2011-12 season decreased slightly. However, what he was lacking in production, he more than made up for with physical play by posting a career best 109 penalty minutes.11 These contributions helped the Club put up 109 points and

5 Supra note 1 6 Ibid. 7 NHL.com, http://www.nhl.com/ice/news.htm?id=544808 8 TSN.ca, http://www.tsn.ca/nhl/teams/players/bio/?id=5722 9 Supra note 1 10 Ibid. 11 Ibid.

2 come within two points of tying the Canucks for the President’s Trophy.12 During the off-season Stewart discovered he had developed a food allergy to brown rice, a staple of his regular diet. This allergy slowed down Stewart’s metabolism and caused him to feel sluggish.13

This no doubt manifested itself on the ice throughout the season as he was continually frustrated with his own play and posted disappointing numbers. Despite this down season, the Club rewarded Stewart with a one-year $3,000,000 contract as a “show me” contract.14

Stewart certainly took the Club up on their “show me” deal by posting arguably his best offensive season during his PY as he led the Club in goals and points. He also finished tied for

18th overall in league goal scoring, a high-water mark for his career.15 With his food allergy issue behind him, Stewart is back on track to becoming a 30-40 goal scorer who can also bring size and physical play like very few others in the game today.

Before continuing to the selection of comparable players, it is appropriate to review

Stewart’s statistical production over the course of his time with the Club in the NHL.

Year Team GP G A PTS PTS/G PIM PIM/G TOI PPTOI SHTOI 2008-09 COL 53 11 8 19 0.36 54 1.02 12:19 1:08 0:05 2009-10 COL 77 28 36 64 0.86 73 0.95 16:41 2:35 0:02 2010-11 COL/STL 62 28 25 53 0.85 53 0.85 17:29 1:52 0:03 2011-12 STL 79 15 15 30 0.38 109 1.38 15:26 1:33 0:05 2012-13 STL 48 18 18 36 0.75 40 0.83 15:49 2:19 0:00

PART III – SELECTION OF COMPARABLE PLAYERS

The Club used an objective statistic-based formula to select comparable players. All arbitration eligible players from the 2012-13 and 2011-12 seasons were considered in the process

12 NHL.com, Standings, http://www.nhl.com/ice/standings.htm?season=20112012 13 NHL.com. http://www.nhl.com/ice/news.htm?id=664499 14 Supra note 4 15 NHL Player Statistics, http://www.nhl.com/ice/playerstats.htm?navid=nav-sts-indiv#

3 but only the players who met the chosen criteria qualified as comparable players for the purpose of this arbitration. Below is the criteria used to select the Club’s comparable players.

Career to Platform (CTP)

• Within (+/-) 35% of Stewart’s 271 games played

• Within (+/-) 25% of Stewart’s 0.61 points per game

• Minimum 0.75 PIM/G (Based on a lower limit of 70% of Stewart’s 1.07

penalty minutes per game in order to ensure eligible players qualify as at

least as physical as Stewart)

Platform Year (PY)

• Minimum 50% of games played in season

• Within (+/-) 35% of Stewart’s 0.75 points per game

• Minimum 0.66 PIM/G (Based on a lower limit of at least 80% of

Stewart’s 0.75 penalty minutes per game to ensure eligible players were at

least as physical as Stewart in their PY)

The chosen criteria represent a combination of the player’s experience at the NHL level, his production, and aggressiveness on the ice. Experience and production are without a doubt two of the most important and relevant factors in determining a player’s worth to his team. In this case, aggressiveness is also a major relevant factor considering the type of game the Player at Hand is known for playing. The CTP is the time period from the beginning of the player’s career at the NHL level up to an including the season immediately preceding his PY. The PY is the season immediately preceding the player’s arbitration eligibility.

4 Ultimately this process yielded two players who qualified as comparable players in this instance. These players are Milan Lucic, and James Neal. The following is an in-depth comparison of the Player at Hand to each of these players.

PART IV – STEWART AND THE COMPARABLE PLAYERS

Before looking closely at the comparable players in relation to Stewart, it should be noted that the salary being used for comparison purposes is that which the player receives in the first year of his new contract. The rationale behind this is that the purpose of this arbitration is to determine Stewart’s worth to the Club next season and not any other future season he may play.

Considering the average annual value of a player’s contract that extends more than one year gives too much weight to a subjective assessment of a player’s future potential rather than rewarding him based on proven past performance. While future potential is no doubt a valid consideration when determining a player’s worth, for the purposes of this arbitration that potential should be limited to the year immediately after his PY and no further. With this in mind, the below tables outline the statistical performance of Stewart and each comparable player in their respective CTP and PY’s.

Career to Platform Year (CTP) 16 Player NHL Seasons GP G A PTS PTS/G PIM PIM/G Stewart 4 271 82 84 166 0.61 289 1.07 Lucic 5 359 90 127 212 0.59 525 1.46 Neal 4 234 73 64 137 0.59 181 0.77

Platform Year (PY) 17 Player Year GP G A PTS PTS/G PIM PIM/G TOI PPTOI SHTOI Stewart 12-13 48 18 18 36 0.75 40 0.83 15:49 2:19 0:00 Lucic 12-13 46 7 20 27 0.59 75 1.63 16:54 1:58 0:01 Neal 11-12 80 40 41 81 1.01 87 1.09 19:08 3:55 0:01

16 All player statistics sourced from respective player’s official NHL profile page 17 All player statistics sourced from respective player’s official NHL profile page

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Supplemental Statistics:

Career to Platform Year (CTP) 18 Player NHL Seasons G Shots Shooting % GWG PPG Stewart 4 82 647 12.67 12 15 Lucic 5 90 579 15.54 17 18 Neal 4 73 583 12.52 9 16

Platform Year (PY) 19 Player Team Year GP G S S% GWG PPG Stewart St Louis 2012-13 48 18 97 18.6 3 6 Lucic Boston 2012-13 46 7 79 8.9 0 0 Neal Pittsburgh 2011-12 80 40 329 12.2 4 18

A) Milan Lucic

Milan Lucic is a 6’3”, 228lbs left-wing forward who plays for the . He was selected in the 2nd round (50th overall) by the Boston Bruins in the 2006 NHL Entry Draft and has played his entire career within the organization.20 Lucic is recognized as one of the premier power forwards in the NHL and consistently puts up notable points and penalty minute totals. He signed a three-year contract worth an average of $6,000,000 per year that pays him $5,500,000 the year immediately following his PY.21

Lucic and Stewart posted nearly identical points per game numbers (0.59 and 0.61 respectively) during the CTP period and each averaged over 1.00 penalty minutes per game.

Both players have also reached the 20-goal plateau twice in their careers (Lucic in 2010-11 &

2011-12 and Stewart in 2009-10 & 2010-11) with Lucic barely cracking the 30-goal plateau in

2010-11 when he registered 30 goals in 79 games. Stewart meanwhile posted back-to-back 28 goal seasons (once while only playing 62 games during the season) and was scoring at pace

18 All player statistics sourced from respective player’s official NHL profile page 19 All player statistics sourced from respective player’s official NHL profile page 20 NHL Player Profile, http://blues.nhl.com/club/player.htm?id=8473485 21Capgeek Player Contract History, http://www.capgeek.com/player/220

6 during the 2012-13 shortened lockout season that would have given him his first 30-goal season in a full 82 game schedule.

Furthermore, Stewart led his team in both goals and points during his PY while Lucic only ranked 7th in goals and 5th in points on his club during his PY.22 These rankings highlight their overall contributions to their respective club’s success. Without a doubt, Stewart was more of an offensive catalyst for his club. With respect to ice time, both players average very similar time on ice and power-play time with the real difference being Stewart scoring 6 power-play goals to Lucic’s zero.

Lastly, both players are built roughly the same with Stewart being only 1” shorter (6’2” compared to Lucic at 6’3”) and 3lbs heavier (231lbs to Lucic’s 228lbs). They are both durable players with the lowest percentage of games played in a season being Lucic in 2009-10 when he played in 61% of his club’s games. Overall, Stewart and Lucic play a very similar style of aggressive game and are valuable contributors to their team’s success.

B) James Neal

James Neal is a 6’2”, 208lb, left-winger who plays for the . The

Dallas Stars drafted him in the 2nd round (33rd overall) of the 2005 NHL Entry Draft. Neal signed a six-year deal during his PY that paid him a flat $5,000,000 in each of the six years.23 Like

Lucic, Neal is regarded as an elite NHL power forward. Unlike Lucic, the balance between offensive production and physicality with Neal is geared more towards production than physicality. In the three years leading up to their PY, Stewart registered 71 goals compared to 73 from Neal, a negligible difference. Looking at their physical play during their respective CTP it

22 Supra note 15. 23 Capgeek Player Contract History, http://capgeek.com/player/693

7 is clear that Stewart has been the more physical player with an average of 1.07 penalty minutes per game compared to Neal’s 0.77.

Neal had a career best season during his PY posting 40 goals, 1.01 points per game and

1.09 penalty minutes per game. These numbers represent a significant increase over his past performance levels. This marked increase in both offensive production and physical play are directly traceable to playing an entire season on the top line alongside 2011-12 NHL leading scorer and MVP . As a result of this complimentary role on the team, Neal’s point total increased accordingly and his penalty minutes rose due to being called upon to protect one of the NHL’s best players. When comparing the shooting percentage of both players from the beginning of their careers through to the end of their PY, Stewart comes out on top sporting a

13.4% compared to 12.4% for Neal.24 This only serves to underscore the elite scoring ability

Stewart possesses.

PART V – CONCLUSION

Given the similarities between Stewart and the comparable players, the Player and his representatives respectfully contend that a salary in excess of $4,150,000 is well deserved and justified based on the first-year salaries of the comparable players highlighted in this brief. All three players evaluated in this brief are part of a rare and elite group of young scoring power forwards that command higher salaries; two have been rewarded handsomely for their much sought-after abilities. It is only fair that the third member of this group, Stewart, be rewarded in a similar manner with a contract that reflects the value of his unique combination of skill and physicality as it relates the Club.

24 All player statistics sourced from respective player’s official NHL profile page

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