HOCKEY ARBITRATION COMPETITION OF CANADA

Transcription

1 HOCKEY ARBITRATION COMPETITION OF CANADA CHRIS STEWART vs. ST. LOUIS BLUES Submission on Behalf of St. Louis Blues Salary Mid-Point: $4.15 Million Submitted by Team 6

2 2 TABLE OF CONTENTS I. INTRODUCTION 3 II. OVERALL PERFORMANCE OF THE PLAYER 3 III. NUMBER OF GAMES PLAYED AND INJURY HISTORY 5 IV. LENGTH OF SERVICE 6 V. OVERALL CONTRIBUTION TO THE CLUB 6 VI. SPECIAL QUALITIES OF LEADERSHIP AND PUBLIC APPEAL 7 VII. COMPARABLE PLAYERS 7 A. Patrik Berglund 7 B. Jakub Voracek 8 C. T.J. Oshie 9 VIII. CONCLUSION 10

3 3 I. INTRODUCTION This brief relates to the matter of the salary arbitration involving 25-year-old righthanded forward Chris Stewart 1 and the St. Louis Blues hockey club pursuant to Article 12 of the Collective Bargaining Agreement between the National Hockey League Player s Association and the National Hockey League. 2 This salary arbitration is being commenced at the request of Stewart. 3 Through an analysis of Stewart s past performance and history with the Blues, it will be demonstrated that he is entitled to less than the $4.15 Million salary mid-point figure. This brief will proceed to analyze each of the 6 criteria enumerated in Article 12.9 of the CBA. 4 Our analysis demonstrates Stewart s performance is inconsistent. Despite moments of excellent performance throughout his career, it is the opinion of the Blues that Stewart is fairly entitled to a salary below the $4.15 Million mid-point figure. II. OVERALL PERFORMANCE OF THE PLAYER Table 1. Stewart s NHL Career Statistics 5 Season Team GP G A P +/- PIM PPG SHG GWG S S% COL COL COL STL STL STL TOTAL At 6 2 and 231lbs, Stewart is viewed primarily as an imposing offensive presence with the potential to contribute large offensive numbers. 6 During the season, Stewart made 53 appearances for the Colorado Avalanche, finishing the season with 11 goals and NHL Collective Bargaining Agreement Supra note 2 at s.12.9(g)(ii)(a)-(g)

4 4 assists, though the team failed to make the playoffs. During the season, Stewart set career-highs, as seen in Table 1, while helping the Avalanche to qualify for the play-offs. The Blues lost in the first round to the San Jose Sharks, though Stewart netted 3 goals in 6 games. 7 Stewart continued to display strong offensive play in the season, recording 30 points in 36 games. However, Stewart s performance came at the expense of his defensive presence. Stewart finished the season with a -10 rating, and while he was on the ice his team s save percentage dropped to (4 th worst on the Avalanche). 8 In early 2011, Stewart signed with the Blues and continued to demonstrate impressive scoring ability. 9 The Blues failed to make the playoffs that year. Unfortunately, such exceptional play was not repeated in , when he netted only 30 points in 79 games. That season, he collected 109 penalty minutes, averaging 15:26 on-ice minutes, evidence of his role on the checking line under current coach Ken Hitchcock. 10 Stewart was a healthy scratch for 2 playoff games that season and averaged below 11 minutes a game. 11 Stewart has struggled to perform at his peak levels since joining the Blues, both offensively and defensively. Stewart s offensive struggles are clearly indicated in his PPG statistics in Table 1. Stewart s cumulative NHL career points per game average is 0.63, however, with the Blues he averages only To add, Stewart s shots on goal have diminished with the Blues. With Colorado he averaged 2.71, whereas with the Blues it has fallen to Supra note

5 5 Defensively, his level of performance has been inconsistent and, frankly, unimpressive. Stewarts number of hits per game fluctuates from 0.83 in 2011, 12 to nearly double that in at 1.41, 13 but then back down to 0.85 again in To add, he has a consistently low number of blocked shots each season, though this may be explained by the fact that he is not entrusted to kill many penalty kill minutes. 15 On the opposite side of that coin, Stewart s penalty minutes have increased slightly from 0.99 with the Avalanche to 1.07 with Blues, which puts increased pressure on his team. III. NUMBER OF GAMES PLAYED AND INJURY HISTORY While with the Avalanche in 2010, Stewart missed 21 games with a broken left hand. 16 The injury was sustained in a fight with Kyle Brodziak of the Minnesota Wild when Stewart hit Brodziak in the side of the helmet several times. After being sent to the locker room to serve his 5-minute fighting major in the last three minutes of the 2nd period, Stewart did not return. 17 The following year, Stewart missed only three games with the Blues due to a suspension by the NHL. He was suspended, without pay, for shoving Detroit Red Wings defenseman Niklas Kronwall from behind and into the boards. 18 Although Stewart has not sustained any catastrophic injuries, the nature of his absences from the game is avoidable. Due to his role on the checking-line, tough play is expected of Stewart, but he has demonstrated a lack of discipline and poor judgment. Both his absences were avoidable and suggest Stewart is a liability in a checking role. As his number of hits and penalty minutes increase each season, so does the threat of prolonged absences. 12 Supra note Ibid

6 6 IV. LENGTH OF SERVICE Following his drafting by the Avalanche in 2006, Stewart signed a two-year entry level standard player contract with the club and played the majority of his first two years with the AHL Lake Erie Monsters. He then re-signed for two more years with the Avalanche in 2009 as a restricted free agent. Since 2010, his NHL experience has been split evenly between the Avalanche and the Blues with nearly 3 seasons per club. V. OVERALL CONTRIBUTION TO THE CLUB Stewart s contribution to the club is difficult to assess as he is capable of superior displays of talent, yet prone to long dry spells. For example from April 12 to April 16, 2013 he had 7 points in 3 games and was a +5. However, he had just 4 points in his next 17 games, twice going four games or more without a point and with an overall -2 rating. 19 Furthermore, his playoff performance is sub-standard. In , he scored twice in one game, though remained otherwise without a point and finishing the playoffs with -1 rating. 20 In , he had just one assist in the Blues first-round defeat by the Los Angeles Kings. 21 Stewart is prone to losing his in-game competitiveness. In 2012/2013, there were 21 games out of the 48 he played where he played more than 16 minutes. In those games, his total points are only 11. However, in the games where his play time was less than 16 minutes, often relegated to the third or fourth lines, he had 25 points. What this demonstrates is that when Stewart feels as if he has something to prove, his play improves. However, long zero-point slump suggest he has a questionable competitive edge. Stewart is incapable of consistently playing his best hockey. Furthermore, this makes him a poor choice for playoff plays and limits his usefulness in losing situations. He is never played on the penalty kill. His on-ice penalty-kill 19 Supra note Supra note Supra note 14.

7 7 minutes last season was Although his points are +18 when the team is winning, he is -18 when his team is losing. 23 Stewart is not a player on whom the Club can rely. VI. SPECIAL QUALITIES OF LEADERSHIP OR PUBLIC APPEAL Stewart is not known for being a positive locker room presence; however his tenure with the Blues has made him a stable presence. Stewart is involved in the St. Louis community, participating last season in the Wayne s Road Hockey Warriors Tournament for underprivileged youth. 24 He has also fundraised for the Children s Hospital Charity in St. Louis. 25 In fairness, he also led the Blues in goals and points (22) last season. 26 This high level of play will increase his visibility in St. Louis, if it can be repeated. Stewart was selected as part of the IIHF Canadian team only once in 2011, but the team was underwhelming. The Canadian team struggled throughout the tournament, finishing in fifth place. Stewart scored 2 goals and 2 assists in 7 games but was otherwise unremarkable. 27 VII. COMPARABLE PLAYERS A. Patrick Berglund Patrick Berglund was drafted 25 th overall in 2006 by the St. Louis Blues. In 2013, the Blues signed Berglund to a one-year deal worth $3.25 million. 28 At 6 3 and 217 lbs, Berglund fulfills a very similar role as Stewart on the Blues. Table 2. Berglund s NHL Statistics 29 Season Team GP G A P +/- PIM PPG SHG GWG S S% STL STL STL Ibid All information available at <

8 8 TOTAL With the exception of last season, the 25-year-old Swede has consistently out-scored Stewart. He is a career +13, while Stewart is a career -21. He has the highest shooting percentage in the league with 23%. 30 He leads the Blues in power play goals with 26. In the playoffs, he has 9 points in 19 games. 31 Defensively Berglund also out-played Stewart last season, recording 12 more hits, 11 more blocked shots and 2 less giveaways in an equal number of games. At 16:50 average on-ice minutes last year, he played a full minute more than Stewart per game. He has been with the Blues for the entirety of his NHL career. 32 We submit that Stewart is entitled to a salary much closer to Berglund s than the $4.15 million mid-point. B. Jakub Voracek Jakub Voracek was drafted 7 th overall in 2007 by the Columbus Blue Jackets. He is 6 2 and 214 pounds. He now plays as a second-line, right-wing, power-forward with the Philadelphia Flyers. He signed a 4-year deal in 2012 worth $4.25 million a season. 33 Despite one less year in the NHL, he has played 50 more games than Stewart. 34 The Club respectfully submits that Stewart is worth less than Voracek. Table 3. Voracek s NHL Statistics 35 Season Team GP G A P +/- PIM PPG SHG GWG S S% CBJ PHI PHI TOTAL Ibid All information available at supra note 34.

9 9 Voracek has a career 229 points in 367 games. His point per game average is 0.62, nearly equivalent to that of Stewart. Voracek has much fewer penalty minutes at 163, compared to Stewart s 329. He is a career +5, with 9 game winning goals and a shooting percentage of 10.4%. He averages 15:37 on-ice minutes; a minute less than that of Stewart. Voracek has 11 playoff goals in 15 games. 36 Voracek has never missed more than three regular season games since he began playing in the NHL. Voracek is more valuable as a long term performer. He is dependable, and a consistent point producer. This is the major distinguishing factor between these players. His offensive zone starts are at 49%, while his offensive zone finishes are at 53.2%. 37 This suggest that Voracek is able to use his size to get the puck down ice. He is not entrusted to finish the goal, but rather to make the play. It is this central responsibility which values Voracek higher than Stewart. Finally, Voracek has far superior locker room qualities. He has been featured in the Czech Republic international team for the past 7 years. He was rated the NHL Star of the Week ending Feb 24 in 2013, leading the league in points and earning four points in one game that week. He won the Bobby Clarke trophy and Pelle Lindhberg Memorial Trophy on the Flyers, as voted by the team. 38 He is capable of being a leader and inspiring his teammates, unlike Stewart. C. T.J. Oshie Table 4. Oshie s NHL Statistics 39 Season Team GP G A P +/- PIM PPG SHG GWG S S% STL STL STL TOTAL Information available at <

10 10 T.J. Oshie is a 5 11, 189 lb right-wing on the St. Louis Blues. The Club drafted Oshie 24 th overall in After 5 seasons with the Blues, he arbitrated a 5 year contract for $4.175 million per season. 40 Oshie plays more minutes than Stewart, averaging 19:05 on-ice minutes 41, and has averaged between 0.63 and 0.69 points per game in each of his NHL seasons. 42 Oshie is a career +35 while Stewart is a career Oshie has been rightly valued higher because of his reliability and consistency as a player. He begins his shifts in the offensive zone only 44.6% of the time, meaning that he is entrusted to generate offense. 44 He has also scored at least one shorthanded goal in each of his five NHL seasons. 45 Stewart, in playing fewer minutes, in a less central role, and proving to be an inconsistent performer is not deserving of either the length or amount of Oshie s salary. Oshie is salient as a comparable despite his longer term deal because he establishes what a reasonable salary would be, if Stewart were to assume a primarily offensive role on the Blues. Stewart s toughness and defensive capabilities are what distinguish him from other forwards. However, Stewart has misused and sacrificed these essential elements of his game, respectively. Thus, he has sacrificed his overall value as a player. VIII. CONCLUSION Stewart is prone to costly lapses in judgment and long point-less stints. Thus, the Blues should not be asked to pay more for Stewart. Until such time as Stewart displays peak performance and a consistent competitive edge for the majority of the season, the Blues submit he is entitled to a salary below the $4.15 million mid-point Supra note Supra note 39.