2013 HOCKEY ARBITRATION COMPETITION OF CANADA

Chris Stewart v. The St. Louis Blues

Submission on Behalf of The St. Louis Blues

Midpoint: $4.15 million

Submission by Team 27

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I. INTRODUCTION

In accordance to Article 12 of the Collective Bargaining Agreement ("CBA") between the ("NHL") and the National Hockey League Players Association

("NHLPA"), Chris Stewart ("the Player" or "Chris") of the St. Louis Blues has elected to pursue salary arbitration to determine his compensation for the 2013-2014 season.

According to the CBA, the following evidence is to be considered in determining a player's salary arbitration compensation: overall performance including NHL official stats of player in previous seasons; the number of games played by the player, his injuries or illnesses during the preceding seasons; the length of the service of that player to the Club; the overall contribution of the player to the Club; any special qualities of leadership or public appeal; the overall performance of players alleged to be comparable to the Player whose salary is in dispute; and the compensation of players alleged to be comparable to the Player whose salary is in dispute.1

St. Louis has considered such evidence and takes the position that Chris should be compensated less than the $4.15 million midpoint salary. The Blues respectively believe that a reasonably salary for Chris is close to $3 million.

II. OVERALL PERFORMANCE OF THE PLAYER

A) Introduction to Chris Stewart and Career Performance

Chris Stewart is a 6'2", 231 lbs right winger who has played 319 NHL games with the

Colorado Avalanche and the St. Louis Blues.* Throughout his professional career, and even as a

1 Collective Bargaining Agreement Between NHL and NHLPA, 2012, Article 12.9 (g) (ii). * All statistics on Chris Stewart throughout this paper are from nhl.com, unless otherwise posted.

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junior player for the Kingston Frontenac's, Chris has primarily been a productive power forward, mixing production with physical play. In three seasons with the Kingston Frontenac's of the Hockey League ("OHL"), Chris accumulated 199 points and 271 minutes in

187 games. Due to such a successful junior career, Chris was drafted by the in the first round, 18th overall, in 2006.

Chris did not jump straight from the OHL to the NHL. After he was drafted, Chris went back to play for the Frontenac's for one more season. He then spent his first year as a professional playing for Colorado's minor league affiliate Lake Erie Monsters of the American

Hockey League ("AHL") where he played 77 games and had 44 points during the 2007-08 season. Chris continued to struggle to find a permanent roster spot on the Avalanche during

2008-09 although he did play what is considered his first full NHL season.* During the 2008-09 season as a member of the Avalanche he played in 53 games and had 19 points and 54 penalty minutes. One of the key factors that kept Chris out of a permanent role in the NHL at this point was his struggle to adapt to playing sufficient defence.2

In the 2009-10 season, Chris played 77 games with the Colorado Avalanche where he accumulated 64 points and 73 penalty minutes. This adds up to 0.83 points per game, which is a very strong showing for his first year with a permanent roster spot in the NHL. Based on his strong play, Chris resigned with the Avalanche for $2.85 million in the 2010 off season.3 He backed up his contract with the Avalanche with strong play in the beginning 2010- 11 season before he was traded to the St. Louis Blues, along with , for Eric Johnson.4 He

2 http://forecaster.thehockeynews.com/hockeynews/hockey/player.php?5722 3 http://capgeek.com/player/560 4 Ibid at note 2. * Based on playing in 10 or more NHL regular season games.

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kept up his strong season in St. Louis, where he ended the season with a 0.84 points per game average, surpassing his average from the previous year.

However, Chris failed to maintain his scoring ability from the previous two years in

2011-2012, and came under much scrutiny from Blues head Coach Ken Hitchcock about his lack of consistency and defensive struggles.5 His point per game average dropped considerably from

0.85 in his previous season, to a dismal 0.38. He also amassed 109 penalty minutes during that season. Although he struggled, the Blues resigned Chris to a one year contract worth $3 million in the following off season.

Leading into the 2012-13 season, his platform year, Chris made it clear that he wanted to become more consistent, and return to the form he was in just two years earlier.6 His inconsistent play, and increase in penalty minutes could be viewed as reasons why he did not sign a larger contract after two strong seasons with the Avalanche and his early play with the

Blues. Although his ice time has remained fairly consistent through the three seasons leading up to his platform year, just around 16:30 per game, his points and penalty minutes were inconsistent (See Figure:1). This type of inconsistency can make it difficult to determine what type of player Chris is. It can be argued that Chris is a gifted scorer, but it can also be argued that he plays more of a physical role. Figure: 1 Season Team GP G A P PIMS TOI PPG 2009-10 COL 77 28 36 64 73 16:41 0.83 2010-11 COL/STL 62 28 25 53 53 17:29 0.85 2011-12 STL 79 15 15 30 109 15:26 0.38

5Hitchcock Sends Message to Stewart: http://www.cbc.ca/sports- content/hockey/opinion/stanleycup2012/2012/04/hitchcock-sends-message-with-chris-stewart-benching.html 6 http://forecaster.thehockeynews.com/hockeynews/hockey/player.php?5722

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B) Platform Year: 2012-13

Chris Stewarts platform year was during the limited 48 game 2012-13 season due to the

NHL lockout. In this short season, Chris showed signs of his offensive capabilities again. In 48

games, Chris scored 36 points, which is 0.75 points per game during a season where he again

received similar ice time to his previous season (See Figure: 2). Chris also limited the number of

penalties he took although he severely dropped in the number of hits per game he had from the

previous season (See Figure: 2). While he did increase his play from the dull previous season, he

did not produce the 0.84 points per game total from two seasons prior. Figure: 2 Season Team GP G A P PIMS TOI PPG Hits/Game 2011-12 STL 79 15 15 30 109 15:26 0.38 1.42 2012-13 STL 48 18 18 36 40 15:49 0.75 0.85

The St. Louis Blues respectively feel that Chris is a player who has great upside however

is still a work in progress.7 The inconsistency in his game can be viewed as proof of that. Chris

is a big physical presence on the ice with proven scoring touch, however in order for him become

a great power forward, Chris must find consistency in scoring while maintaining physical play.

This means that Chris needs to prove that he can maintain over a hit per game while

accumulating the points he is capable of. Taking this into consideration, St. Louis believes Chris

should be making a salary somewhere between the $3 million he made last season, and the $4.15

million midpoint salary.

7 http://forecaster.thehockeynews.com/hockeynews/hockey/player.php?5722

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C) Playoff Experience

Chris Stewart has played in three different playoffs. His first came in 2010 playing for Colorado where they lost in six games in the first round. Chris played solid during this series scoring 3 goals and averaging over 17 minutes of ice time. However, the two playoff performances Chris has with the St. Louis Blues have not been as strong. During the 2012 playoffs, his first with the Blues, Chris saw limited ice time and was a healthy scratch during the

Blues first round loss.8 This lead Head Coach Ken Hitchcock to publicly question the consistency, defensive ability, and the future role the Player would have with the St. Louis

Blues.9

The Blues also made the playoffs during Chris's platform year. Chris was the team's leading scorer throughout that season, however he had a very poor playoff performance. Chris only had 1 point while receiving ice time that was consistent with his season ice time. This again lead coaching staff to question his consistency as a top player. The coaching staff felt that as the team's top point getter, Chris is expected to contribute offensively at a high level in important games like the playoffs.10

D) Injuries and Suspensions

Chris has had two reported injuries throughout his career. During his first full season in the NHL with the Colorado Avalanche, Chris missed 3 games with a head injury.11 While one head injury historically leads to further head related injuries, Chris has had no further head related issues. Chris also missed 21 games in 2011 due to a broken hand he sustained in a fight

8 Supra note 5. 9 Ibid. 10 http://forecaster.thehockeynews.com/hockeynews/hockey/player.php?5722 11 http://www.tsn.ca/nhl/teams/players/bio/?id=5722

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with Kyle Brodziak.12 With the physical game that Chris is known to play, it increases the risk

of injury throughout the season. While being a physical player is part of the Players game, the

St. Louis Blues have taken such risks into consideration, and believe it is reasonable to believe

that there is a possibility that Chris could miss games due to injury throughout a season. It is

also true that Chris has not played every game in any of his seasons in the NHL except for the

shortened 48 game season in his platform year.

On November 15th, 2011 Chris hit defenseman Niklas Kronwall from

behind leading the NHLs Department of Player Safety to suspend Chris for three games. Under

the CBA, repeat offenders will be more severely punished for each new violation.13 The risk of

signing a repeat offender will also be taken into consideration by the St. Louis Blues.

III. COMPARABLE PLAYERS

A) Derek Stepan

Derek Stepan is a 6'0", 196 lbs first line center for the . He was

drafted in 2008 and played his first full season with the Rangers in 2010-11. Derek played for

University of Wisconsin before making the jump right to the NHL where he played in all 82

games during his first professional season with the Rangers. Derek is a comparable player to

Chris Stewart as they are both offensive while distributing similar amount of hits per game.

Both players had their platforms years in 2012-2013 as well. Figure: 3 (Derek Stepan Statistics, Platform Year: 2012-13)

Season Team GP G A P PIMS TOI PPG Hits/Game 2011-12 NYR 82 17 34 51 22 18:56 0.62 1.08 2012-13 NYR 48 18 26 44 12 20:55 0.92 1.67

12 http://www.tsn.ca/nhl/teams/players/bio/?id=5722 13 Supra note 1 at Article 18. 2 (c).

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In his platform year, Derek scored 18 goals while scoring 44 points in 48 games, good

enough for 0.92 points per game. Derek played in all regular season games last season, in fact,

Derek has not missed an NHL regular season game for the Rangers in his three year career. He

not only plays more minutes than Chris, but Derek has averaged more hits per game than Chris

over the last two years while accumulating less penalties and no injuries. He has also achieved a

plus/minus rating well above what Chris has over the last two seasons, making him more

responsible defensively while still contributing more offensively (See Figure: 4).

Figure: 4 (Comparison: Platform Year) Platform Year Compensation GP G A P PIMS +/- PPG Hits/Game Derek Stepan $3,075,000 48 18 26 44 12 +25 0.92 1.67 Chris Stewart X 48 18 18 36 40 0 0.75 0.85

In the 2013 offseason Derek Stepan re-signed with the Rangers to a two year contract

worth $3.075 million annually.14 Given that Derek has a greater points and hits per game

average, as well as a significantly higher plus/minus while playing more minutes, the St. Louis

Blues respectively view Derek as a more complete NHL player. Derek has never missed a

regular season game in his three season with the Rangers while still averaging over a hit per

game and playing solid defense with a very strong plus/minus. Chris only has one season where

he played in all regular season games; the lockout 48 game season. Chris has also struggled with

injury and discipline throughout his career, and has missed games because of that. The Blues

should take the following into consideration and find a slightly lower compensation for Chris

than that of Derek Stepans.

14 http://www.tsn.ca/nhl/teams/players/bio/?id=6917

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B) Brad Boyes

Brad Boyes is a 6'0", 195 lbs right winger who recently signed a one-year contract with

the worth $1 million. Brad is a comparable player to Chris Stewart because of

the inconsistency evident in their games. Both players also had similar points per game and hits

per game during their platform years.

Brad has played eight seasons in the NHL and has found great success in some, and has

played poorly in others. For example, in 2011-12, Brad played in 65 games accumulating 23

points, for a point per game average of 0.35. Then in 2012-13, his platform year, Brad played in

all 48 games accumulating 35 points, for a point per game average of 0.75. This inconsistency to

perform offensively can be viewed throughout his entire career (See Figure: 5).

Figure: 5 (Brad Boyes- Points Per Game Per Season)

Season 05-06 06-07 07-08 08-09 09-10 10-11 11-12 12-13 PPG 0.84 0.57 0.79 0.88 0.51 0.66 0.35 0.73

This inconsistency can be comparable to that of Chris, especially in his last two seasons.

In fact, Chris and Brad have almost identical points per game averages in 2011-12, and their

platform year of 2012-13. Figure: 6 Season (11-12) GP G A PTS PPG Hits/Game PIMS Compensation Stewart 79 15 15 30 0.38 1.42 109 Boyes 65 8 15 23 0.35 0.45 6 Season (12-13:Platfrom Year) GP G A PTS PPG Hits/Game PIMS Compensation Stewart 48 18 18 36 0.75 0.85 40 X Boyes 48 10 25 35 0.73 0.92 16 $1 000 000

We can see from Figure: 6 that Chris and Brad had inconsistent seasons in 2011-12 to

2012-13. While both players played well in their platform years, it must not be overlooked that

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they bother were coming off poor years the year before. It also must be noted that Brad missed

13 games due to a knee injury. Chris has also missed a significant number of games due to injury during his career (See D) Injuries and Suspensions, page 5). The St. Louis Blues must take the inconsistency and games missed due to injury into consideration.

IV. CONCLUSION

Chris Stewart is a big, physical forward who has a great upside on the offensive side of the puck. He had a very strong platform year and this should be taken into consideration.

However, he has struggled defensively throughout his career which was publicly expressed by coaching staff and fellow players. Chris has also had injury problems in the past, and is a repeat offender under the new CBA and this should also be taken into consideration.

In comparison to Brad Boyes and Derek Stepan, the St. Louis Blues respectively see greater contribution to a team compared to Brad, which means compensation should be greater than that of Brads $1 million salary. However, the Blues should consider Derek as a player that

Chris could potentially become with another year under his belt in the NHL. The Blues respectively believe Chris deserves compensation close to the $3.075 million that Derek makes annually.

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