2013 HOCKEY ARBITRATION COMPETITION OF CANADA

St. Louis Blues v. Chris Stewart October 4, 2013 Submission by Team 1

I. INTRODUCTION

This brief discusses the 2013 contract negotiations of Chris Stewart (the “Player” or “Mr.

Stewart”) of the St. Louis Blues (the “Club” or the “Blues”). This is the fourth National Hockey

League (“NHL”) contract to which Mr. Stewart is a party, the first of which commenced in the

2007-2008 season.1 Having acquired the requisite four years of professional experience, Mr.

Stewart became eligible and filed for NHL salary arbitration in 2013, pursuant to section 12.1 of the Collective Bargaining Agreement (“CBA”).2 3 On July 19, 2013, Mr. Stewart avoided the arbitration process by agreeing to a two-year contract with an annual average value (“AAV”) of

$4.15 million. 4

As enumerated in the CBA, only the following criteria may be provided as evidence: 5

a) Overall performance of the player in the NHL throughout his career

b) Number of career NHL games played with consideration to injuries or illness

c) The length of service of the Player in the league and/or with the Club

d) Overall contribution of the Player to the success or failure of his Club in the

preceding season

e) Special qualities of leadership or public appeal

f) Overall performance of any Player(s) alleged to be comparable to the party Player

g) The compensation of any eligible Player(s) mentioned in (f)

1 http://capgeek.com/player/560 2 http://www.nhlpa.com/news/2013-14-salary-arbitration-schedule 3 Collective Bargaining Agreement, 2013, s. 12 4 http://www.tsn.ca/nhl/teams/players/bio/?id=5722 5 Supra note 3 2

Analysis of these criteria throughout this brief establishes that fair market value for a player with

Mr. Stewart’s statistics and history in the league is $3.81 million. As such, the St. Louis Blues organization request that the panel find that he is entitled to a salary arbitration award in this amount.

II. Evaluation of Mr. Stewart

A. Overall Performance

During his first three seasons in the NHL, Mr. Stewart was producing at an exceptional rate – over 0.8 points per game in each season. Unfortunately, the Player has been unable to maintain this level of production as his points per game dropped in his last two seasons (0.75 in the lockout shortened Platform season). His career low occurred in the 2011-2012 with only 0.38 point per game.

Table II.A.i): Regular Season statistics for the Player6

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

2008-2009 AVALANCHE 53 11 8 19 -18 54 1 1 1 98 11.2

2009-2010 AVALANCHE 77 28 36 64 4 73 3 0 5 221 12.7

2010-2011 AVALANCHE 36 13 17 30 -10 38 5 0 3 95 13.7

2010-2011 BLUES 26 15 8 23 4 15 7 0 2 67 22.4

2011-2012 BLUES 79 15 15 30 1 109 2 0 1 166 9

Regular Seasons Regular 2012-2013 BLUES 48 18 18 36 0 40 6 0 3 97 18.6 NHL TOTALS 319 100 102 202 -19 329 24 1 15 744 13.4

6 Compiled from nhl.com 3

Mr. Stewart has made three post season appearances, playing in 19 total games. His 0.31 points per game in playoff games is well below his regular season rate. In six in his platform season, he managed only one assist.

Table II.A.ii): Playoff statistics for the Player7

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

2009-2010 AVALANCHE 6 3 0 3 -1 4 0 0 1 20 15

2011-2012 BLUES 7 2 0 2 -1 12 0 0 0 13 15.4

2012-2013 BLUES 6 0 1 1 0 0 0 0 0 17 0

Playoffs NHL TOTALS 19 5 1 6 -2 16 0 0 1 50 10

B. Number of Games Played & Injury History

In five seasons, Mr. Stewart has played 319 career NHL games. Since the Player began starting regularly in the NHL, he has missed 24 games due to injury and 3 to suspension8.

In 2009, while playing for Lake Erie of the AHL,