Team 10

Chris Stewart

Player’s Side

I) Introduction

This brief will analyze St. Louis Blues (the “Blues” or the “Club”) forward Chris

Stewart’s (“Mr. Stewart”) contributions on and off the ice, in the support of Mr. Stewart’s upcoming arbitration hearing. The purpose of this brief is to outline the reasons for which Mr.

Stewart should be entitled to a salary greater than the $4.15 million figure set as the mid-point.

Mr. Stewart is a 25-year-old Canadian born, right-handed, right-winger who played the most recent NHL season with the St. Louis Blues. Prior to the beginning of the 2007/2008 NHL season, Mr. Stewart signed a three-year entry level Standard Player Contract (“SPC”) with the

Avalanche. Since then Mr. Stewart has earned six years of professional experience, and as such is eligible for salary arbitration in accordance with section 12.1 of the Collective Bargaining

Agreement (“CBA”).1

As outlined in section 12.9(g) of the CBA, the following evidence may be introduced in support of an arbitration award: overall statistical performance of the player in previous season

(both offensive and defensive statistics); the number of games played by the Player; the length of service of the player (in the league and/or with the club); the overall contribution of the Player to the competitive success or failure of the Club in the preceding season; any special qualities of leadership or public appeal; the overall performance and salary of players who are alleged to be comparable to the Player whose salary is in dispute.2 This brief will be address each of these points individually.

1 NHL Collective Bargaining Agreement, 2012, s. 12.1(a)-(c), available online: 2 Ibid at s.12.9(g)(ii)(A)-(G). After having considered the evidence presented in this brief, it will be clear that Mr.

Stewart’s statistical play, as well as his intangible assets, warrant a salary arbitration award of greater than $4.15 Million.

II) Mr. Stewart’s Overall Performance

A) Career Performance

Table 1: Mr. Stewart’s career statistics

Mr. Stewart has been a very effective player over the course of his career. Known for his physical play and sizeable presence, at 6’2” and 231 pounds3, Mr. Stewart has shown throughout his career a notable ability to score points. In his first full professional season with the Lake Erie

Monsters, Mr. Stewart lead the team in scoring with 25 goals, finishing third in total points.4

While Mr. Stewart’s NHL career started off slowly, he finished with only 19 points in 53 games as a rookie (0.36 points/game), it is important to note that during that season the Avalanche finished last in the league, scoring a league low 199 goals.5 In the 2010/2011 season, he averaged

3 Ibid. 4 http://www.lakeeriemonsters.com/team/stats/ 5 http://avalanche.nhl.com/club/standings.htm?season=20082009&type=CON a career best 0.85 points per game, tying him with John Tavares for 40th overall in the league in this category.6

Furthermore, throughout Mr. Stewart’s career he has consistently been matched up against the opposing teams tougher players. Mr. Stewart’s Relative Corsi Quality of Competition

(“RCQC”)7 is evidence of this fact, which has been above zero (0) for every season, with the exception of his rookie year, indicating that he is matched up against tougher competition than his fellow teammates.8

B) 2012/2013 Regular Season for Chris Stewart

Table 2: Chris Stewart’s regular season statistics

Mr. Stewart averaged 0.75 points per game during the regular season, finishing first on the team in goals (25th overall in the league) and points (David Backes scored the team’s second highest total, eight points less than Mr. Stewart)9. Furthermore, Mr. Stewart showed that he is a proficient point-producer on the power play, leading the team with 12 points and six goals.10

Although a productive offensive player, Mr. Stewart also had a good year defensively, finishing with 41 hits, 13 blocked shots, 13 takeaways.11

6 http://www.nhl.com/ice/playerstats.htm?fetchKey=20112ALLSASALL&viewName=points&sort=avgPointsPerGame&pg=2 7 The Relative Corsi Quality of Competition is used to compare the quality of competition when the player is on the ice. 8 http://www.behindthenet.ca/nhl_statistics.php?c=0+1+3+5+4+6+7+8+13+14+29+30+32+33+34+45+46+63+67&ds=1&f3=CHRISSTEWART &f1=2012_s+2012_p+2011_s+2011_p+2010_s+2009_s+2009_p+2008_s 9 http://www.nhl.com/ice/playerstats.htm?season=20122013&gameType=2&team=STL&position=S&country=&status=&viewName=summary# 10 http://www.nhl.com/ice/playerstats.htm?gameType=2&position=S&season=20122013&sort=powerPlayGoals&status=A&team=STL&viewNam e=scoringLeaders 11 http://www.nhl.com/ice/player.htm?id=8473485&view=splits C) 2012/2013 Playoff for Chris Stewart

Table 3: Chris Stewart’s playoff statistics

Unfortunately, during the 2012/2013 playoffs, Mr. Stewart scored only one point and the

Blues were eliminated in six games. It is important to note that while Mr. Stewart scored only one point in six games, the Blues struggled as a team scoring only 10 goals in the playoffs.12

III) Number of Games Played and Injury History

As mentioned above, Mr. Stewart entered the NHL in 2008/2009 and since then has played 319 games of a possible 346.13 This amounts to an exceptionally low average of 5.4 missed games per season. On November 28th, 2010 during a fight against Kyle Brodziak of the

Minnesota Wild, Mr. Stewart hit Mr. Brodziak’s helmet a number of times resulting in Mr.

Stewart breaking his hand. This injury forced Mr. Stewart to miss 21 games.14 While this injury was serious it should not be weighed very heavily as it is not related to a chronic condition nor is there any reason to believe that it will occur again in the future.

In his first full season with the Blues, Mr. Stewart averaged only 15:26 minutes per game.15 Mr. Stewart played 79 of a possible 82 games, missing only 3 games due to a suspension by the NHL for shoving defenseman Niklas Kronwall from behind. While Mr.

12 http://www.nhl.com/ice/playerstats.htm?fetchKey=20133STLSASALL&sort=goals&viewName=summary 13 http://www.tsn.ca/nhl/teams/players/bio/?id=5722 14 http://bleacherreport.com/articles/528623-chris-stewart-breaks-hand-in-fight-expected-to-be-out-until-2011 15 Ibid. Stewart is known for his physical play, this is his first and only suspension by the NHL.16 Mr.

Stewart also played 7 playoff games, averaging only 10:47 minutes per game, during the Blues’ first round exit from the playoffs.17 In the most recent NHL season, Mr. Stewart played in all 48 games of the lockout-shortened season, averaging 15:39 minutes of ice-time.18 Once again the

Blues made the playoffs only to be eliminated in the first round by the .

During this playoff run Mr. Stewart played in all six games, contributing 16:32 minutes of ice time per game.

As shown above, Mr. Stewart is an extremely durable player with a limited injury history.

Mr. Stewart has played in the vast majority of regular season games for both the Avalanche and

Blues, and has not missed a playoff game with either club.

IV) Length of Service

As mentioned previously, Mr. Stewart was drafted by the Avalanche, in the first round, and played his first two and a half seasons with the club. During his time with the Avalanche Mr.

Stewart played in 166 games before being traded to the St Louis Blues. In the subsequent two and half season with the Blues Mr. Stewart has amassed 153 games of experience.19

V) Overall Contribution to the Club

As mentioned above, Mr. Stewart has been a significant offensive contributor, finishing with 18 goals in the most recent season. In percentage terms, Mr. Stewart scored 14% of the

16 http://www.nhl.com/ice/news.htm?id=601861 17 http://www.nhl.com/ice/player.htm?id=8473485&view=splits&season=20112012&gameType=3 18 http://www.nhl.com/ice/player.htm?id=8473485&view=splits&season=20122013&gameType=2 19 http://blues.nhl.com/club/player.htm?id=8473485 Club’s goals, while averaging 2.17 points per 60 minutes of ice time.20 Mr. Stewart’s contributions to the Blues offense can be seen more clearly when comparing the 3.21 goals for while Mr. Stewart is on the ice, in comparison to the 1.78 goals for while Mr. Stewart is off the ice.21 Since the hiring of Coach Ken Hitchcock on November 6th, 2011, the Blues have achieved a great deal of success as a club, a great deal of which is due to their defensive play. Not only has

Mr. Stewart contributed offensively but he has been successful at stopping the opposition’s tougher players (as shown by his RCQC of 0.67222), having an on-ice plus/minus of 0.28 per 60 minutes of ice time in comparison to the teams 0.00 plus/minutes when he was off the ice.

VI) Special Qualities of Leadership or Public Appeal

Mr. Stewart brings toughness and intensity to the Blues line-up. As a power forward Mr.

Stewart is often called upon to defend his teammates, which is shown by the fact that he has a history of fighting. In the 2012/2013 season, Mr. Stewart was awarded four fighting majors.

While Mr. Stewart has a history of fighting, as mentioned above, the NHL has only suspended him once.

VII) Comparable Players

A) Kris Versteeg

20 http://blues.nhl.com/club/standings.htm?season=20122013&type=CON and http://www.behindthenet.ca/nhl_statistics.php?ds=20&f1=2012_s&f2=5v5&f3=CHRISSTEWART&c=0+1+3+5+4+6+7+8+13+14+29+30+32+3 3+34+45+46+63+67+17+18+19+20# 21 http://www.behindthenet.ca/nhl_statistics.php?ds=25&f1=2012_s&f2=5v5&f3=CHRISSTEWART&c=0+1+3+5+4+6+7+8+13+14+29+30+32+3 3+34+45+46+63+67+17+18+19+20+21+22+23+24+25+26+27+28 22 http://www.behindthenet.ca/nhl_statistics.php?c=0+1+3+5+4+6+7+8+13+14+29+30+32+33+34+45+46+63+67&ds=1&f3=CHRISSTEWART& f1=2012_s+2012_p+2011_s+2011_p+2010_s+2009_s+2009_p+2008_s At the time of Kris Versteeg’s application for arbitration, he was the same age as Mr.

Stewart. Having earned 321 games of NHL experience, Mr. Versteeg is comparable in terms of experience to Mr. Stewart’s 319 of NHL experience.

GP G A P +/- PIM PPG SHG GWG S%

321 88 113 201 17 198 24 9 12 12.5

During Mr. Versteeg’s career (at the time of arbitration) in the NHL he had scored 201 points in 321 games, an average of 0.62 points per game. This number is directly comparable to

Mr. Stewart’s career 0.63 points per game.23 However, one major difference between these two players can be seen in their RCQC, which shows that Mr. Versteeg has throughout his career played against easier opponents in comparison with Mr. Stewart. Furthermore, in their respective platform years Mr. Versteeg was on the ice for 2.79 goals for per 60 minutes of ice time, which is considerably lower than Mr. Stewart’s statistics of 3.21 goals for. As an indicator of Mr.

Versteeg’s value, the are paying him 7.22% of their total salary.24 Assuming that Mr. Stewart and Mr. Versteeg are of comparable value to their respective teams this would indicate that Mr. Stewart should receive a salary of $4.57 Million.

B) T.J. Oshie

At the time of arbitration, Mr. Oshie had earned 4 years of NHL experience totaling 262 games, all with the Blues. Given the fact that Mr. Oshie and Mr. Stewart both entered the league

23 http://blues.nhl.com/club/player.htm?id=8473485 24 http://www.capgeek.com/player/247 in the 2008/2009 season and the fact that they play for the same team makes them appropriate comparators.

GP G A P +/- PIM PPG SHG GWG S%

262 63 112 175 40 131 13 4 10 11.45

Mr. Oshie is a useful comparator, both as a player of similar age, and as a Blues player.

Mr. Oshie has averaged 0.66 points per game over his career, a number only slightly higher than

Mr. Stewart. As well, Mr. Stewart is a much more reliable scorer than Mr. Oshie, who averages

0.24 goals per game, in comparison to Mr. Stewart’s 0.31 goals per game. Moreover, Mr.

Stewart had a career best 64 points during the 2009/2010 season, while in Mr. Oshie’s best season (2011/2012) he only scored 54 points. This should be interpreted as proof of that Mr.

Stewart has a higher point ceiling. Finally, based on his most recent contract agreement Mr.

Oshie’s salary of $4.175 million composes 6.46% of the Blues total salary.25 If it is concluded that Mr. Oshie and Mr. Stewart are comparable players, this requires that Mr. Stewart be awarded a salary of $4.35 million per year.

VIII) Conclusion

Mr. Stewart is a prototypical power forward, possessing a dynamic combination of strength and skill not found in other offensive players. Comparing Mr. Stewart with Mr. Oshie and Mr. Versteeg’s salaries, it is clear that Mr. Stewart deserves an award of greater than $4.15 million and in the range of $4.35-$4.57 million.

25 http://www.capgeek.com/blues/