~ BRIEF IN SUPPORT OF CARL GUNNARSSON ~ IN THE MATTER OF SALARY ARBITRATION BETWEEN: CARL GUNNARSSON AND THE TORONTO MAPLE LEAFS WINDSOR TEAM 1
2 TABLE OF CONTENTS I. INTRODUCTION... 3 II. ABOUT CARL GUNNARSSON... 3 III. COMPARABLE PLAYERS... 5 A. Kyle Quincey... 5 B. Karl Alzner... 7 C. Marc Methot... 9 IV. CONCLUSION... 10
3 I. INTRODUCTION This brief is in support of Carl Gunnarsson s position in the salary arbitration with the Toronto Maple Leafs. Mr. Gunnarsson s election of salary arbitration is appropriate pursuant to Article 12.1 of the Collective Bargaining Agreement (CBA). The following evaluation of Mr. Gunnarsson will be conducted by way of comparison with Kyle Quincey, Karl Alzner, and Marc Methot. Based on an evaluation of Mr. Gunnarsson s career statistics, his platform season, and his overall contribution the club, he respectfully submits that the arbitrator award him a one-year Standard Player Contract (SPC) in the amount of $3,400,000. II. ABOUT CARL GUNNARSSON Carl Gunnarsson is a 6 2, 189lbs Swedish defenseman who has spent his entire NHL career with the Toronto Maple Leafs. He was drafted by the organization with the 194th overall pick in the 2007 NHL entry draft. Mr. Gunnarsson has played four seasons with the club from 2009-2010 through 2012-2013 as a playmaking, stay-at-home defenseman. 1 This year, Mr. Gunnarsson will transition from being a group 2 player to a group 3 player by virtue of turning 27-years-old. As a result, under the current CBA, namely Article 12.9(c), he can only be awarded a one-year SPC. 2 Table 1: Carl Gunnarsson s Career Statistics 3 Season GP G A P P/GP PIM ATOI SH-ATOI 2009-2010 43 3 12 15.35 10 21:26 2:46 2010-2011 68 4 16 20.29 14 18:14 2:36 2011-2012 76 4 15 19.25 20 21:42 2:38 2012-2013 37 1 14 15.41 14 21:16 2:35 Career 224 12 57 69.31 58 - - 1 http://www.nhl.com/ice/player.htm?id=8474125#&navid=nhl-search. Note that career totals have changed since the start of the 2013-2014 regular season 2 Article 12.9(c), the pertinent part reads, (i) the Club or Player, as the case may be, shall be entitled to elect only a one-year SPC if the Player is within one (1) year of attaining the age and experience level required for Group 3 Player status 3 Supra note 1. ATOI and SH ATOI can be found by selecting the appropriate season, http://www.nhl.com/ice/player.htm?id=8474125&view=splits
4 Through his professional career, Mr. Gunnarsson has shown exceptional development with a consistently upward trajectory. During the 2006 to 2009 seasons, Mr. Gunnarsson played in the Swedish Elite League. 4 Since transitioning into the NHL in the 2009-2010 season, Mr. Gunnarsson has established himself as a top-2 defensemen with the Toronto Maple Leafs. In 224 career games, Mr. Gunnarsson has posted 69 points while accumulating only 58 penalties minutes. 5 His average time on ice on special teams identifies that he has settled into a stay-at-home defenseman role, playing top minutes while shorthanded and seldom playing on the power play. With a relatively injury-free career and no ongoing physical concerns, Mr. Gunnarsson has become a durable defenseman who can play against top NHL lines. 6 Table 2: Mr. Gunnarsson s Platform Season Statistics, 2012-2013 7 GP G A P P/GP PIM BkS Hits ATOI SHATOI Shifts/G 37 1 14 15 0.41 14 71 78 21:16 2:35 30.3 In 2013, his platform season, Mr. Gunnarsson played on the top defensive pairing with team captain Dion Phaneuf. Considered the playmaker of the two, Mr. Gunnarsson notched 14 assists and 1 goal in 37 games. 8 Mr. Gunnarsson averaged 30.3 shifts per game, ranking 2nd on his team and 7th amongst defensemen in the league. 9 Mr. Gunnarsson s platform season statistics demonstrate offensive upside during evenstrength play. Mr. Gunnarsson s 14 even-strength assists ranked tied for 6th amongst all NHL defensemen. His 15 points over 37 games is also noteworthy for being the highest even strength points-per game amongst defensemen on his club with.41 P/GP. 10 4 Supra note 1 5 Ibid 6 http://www.tsn.ca/nhl/teams/players/bio/?id=5218 7 Supra note 1; Supra note 3 8 Supra note 1; Mr. Gunnarsson played in 37 games of the 48-game season due to slight muscle irritation in his hip. 9 http://www.nhl.com/ice/playerstats.htm?fetchkey=20132alldadall&sort=avgshiftspergame&viewname=tim eonice 10 Supra note 1
5 Defensively, Mr. Gunnarsson s stay-at-home play has been effective without drawing unnecessary penalties. Of his 14 penalty minutes, none were majors or misconducts. His tempered physicality has not deterred him from landing 78 hits and 71 blocked shots. 11 At the international level, Mr. Gunnarsson has represented Sweden at the World Hockey Championships on 3 occasions from 2009-2011 and helped Sweden capture a bronze medal in 2010 and a silver medal in 2011. 12 III. COMPARABLE PLAYERS As a player who will be 27-years-old on July 1st, 2014, Mr. Gunnarsson is restricted to a one-year SPC under Article 12.9(c) after which he will become an Unrestricted Free Agent (UFA). 13 No other defenseman has gone to arbitration under these circumstances in recent years; many have signed contracts prior to arbitration that include a term of longer than one or two years. Given this bargaining disadvantage, the closest comparable players available to assess a fair and reasonable SPC for Mr. Gunnarsson are Kyle Quincey, Karl Alzner, and Marc Methot. A. KYLE QUINCEY Kyle Quincey is a 28 year-old defenseman currently playing for the Detroit Red Wings. Drafted by the Red Wings in the fourth round with the 132nd overall pick in 2003, Mr. Quincey has played for the Los Angeles Kings in 2008-2009, the Colorado Avalanche from 2009 to 2011 and has since returned to the Detroit Red Wings. Table 3: Mr. Gunnarsson and Mr. Quincey Career Statistics 14 Player GP G A P P/GP PIM Carl Gunnarsson 224 12 57 69.31 58 Kyle Quincey 293 19 79 98.33 268 11 Supra note 3 12 en.wikipedia.org/wiki/carl_gunnarsson 13 See Article 10.1(a)(i) 14 Supra note 1; http://www.nhl.com/ice/player.htm?id=8470724#&navid=nhl-search
6 Both Mr. Quincey and Mr. Gunnarsson spent time in other professional leagues shortly after they were drafted. Since joining the NHL, Mr. Gunnarsson and Mr. Quincey have had similar points per game averages at.31 and.33 respectively. They are both considered stay-athome defensemen and neither play regularly on the power play. Having bounced between three NHL teams over four years, Mr. Quincey has not been able to settle into a defined defensive role on any given team. Conversely, Mr. Gunnarsson has spent his entire NHL career with one team where he has become a top-2 defenseman through his club s rebuilding phase. Table 4: Mr. Gunnarsson and Mr. Quincey Platform Season Statistics 15 Player GP G A P P/GP PIM ATOI SHATOI Carl Gunnarsson 37 1 14 15.41 14 21:16 2:35 Kyle Quincey 72 7 19 26.36 89 21:51 2:18 Mr. Quincey s platform season in 2011-2012 was split between the Los Angeles Kings and the Detroit Red Wings. During their respective platform years, Mr. Quincey and Mr. Gunnarsson logged substantially similar average ice times and shifts per game. Both continued to regularly kill penalties and seldom played on the power play. While Mr. Quincey had more goals in his platform season, both players posted similar point totals and points per game. However, Mr. Quincey s penalty minutes stand out as a difference between his and Mr. Gunnarsson s platform seasons. Over 72 games, Mr. Quincey had 89 penalty minutes while Mr. Gunnarsson only had 14 penalty minutes over 37 games which, pro-rated over 72 games, is still only approximately 27 penalty minutes. 16 While playing similar amounts of ice time in similar roles, Mr. Gunnarsson caused substantially fewer shorthanded situations than Mr. Quincey. 15 Supra note 1; http://www.nhl.com/ice/player.htm?id=8470724&view=splits 16 Supra note 3; http://www.nhl.com/ice/player.htm?id=8470724&view=splits
7 As noted above, Mr. Quincey has not spent a significant amount of time with any single NHL club. His contract therefore did not account for non-statistical factors such as length of service or leadership qualities that have arisen for players like Mr. Gunnarsson. On July 18, 2012, Mr. Quincey was awarded a two-year contract with an average annual value of $3,775,000 after which he will become a UFA. 17 Based on their comparable career statistics and platform statistics, and taking into account Mr. Gunnarsson s length of service and avoidance of penalties, Mr. Gunnarsson should be awarded a similarly valued contract at $3,400,000 over one-year. B. KARL ALZNER Mr. Alzner is a 24-year-old stay-at-home defenseman who plays for the Washington Capitals. He was selected 5th overall by the Capitals in the 2007 Draft, and has played in five NHL seasons. Mr. Alzner is a close comparable based on the similar number of games played, defensive role, and the timing of his most recent contract. Table 5: Mr. Gunnarsson and Mr. Alzner Career Statistics 18 Player GP G A P P/GP PIM Carl Gunnarsson 224 12 57 69.31 58 Karl Alzner 263 5 39 44.17 77 Mr. Alzner and Mr. Gunnarsson s career statistics and trajectory are comparable in that they were both drafted in the same year, have played a similar amount of NHL games, and have similar average time on ice and penalty minutes. Both players also play a similar stay-at-home role and have predominantly played on the penalty kill and not on the power play. 19 Mr. Gunnarsson s career statistics are distinguishable from Mr. Alzner s based on offensive production. Over the course of their very similar careers, Mr. Gunnarsson has amassed 17 http://capgeek.com/player/1008; en.wikipedia.org/wiki/kyle_quincey 18 Supra note 1; http://www.nhl.com/ice/player.htm?id=8473991#&navid=nhl-search 19 Ibid
8 69 points in 224 games played, for an average of.31 points per game, while Mr. Alzner has posted only 44 points in 263 games played, for an average of.17 points per game. Table 6: Mr. Gunnarsson and Mr. Alzner Platform Season Statistics 20 Player GP G A P P/GP PIM ATOI SHATOI Carl Gunnarsson 37 1 14 15.41 14 21:16 2:35 Karl Alzner 48 1 4 5.10 14 20:57 2:34 In his platform season, Mr. Alzner continued to play important minutes on defense posting average ice times and average shorthanded ice times similar to Mr. Gunnarsson s. In addition to comparable time on ice, both players avoided delay of game, major and misconduct penalties while posting identical number of penalty minutes. However, their respective performances in their shared platform season differed greatly with respect to points per game and shorthanded goals against. On the offensive side, Mr. Gunnarsson had four times as many points per game as Mr. Alzner. On the defensive side, Mr. Alzner and his team allowed 18 shorthanded goals (SHGA) while he was on the ice, while Mr. Gunnarsson and his team only allowed 8 SHGA while he was on the ice. 21 Accounting for the difference in the amount of games played, this averages to.38 SHGA for Mr. Alzner, and.22 SHGA for Mr. Gunnarsson. Both drafted in 2007, these two defensemen have grown up in their respective organizations and have made substantially similar contributions to their team with respect to length of service and adding an overall competitive edge. Mr. Alzner, like Mr. Gunnarsson, brings the experience of international success to his NHL club having won two gold medals for Canada in World Junior Championships. 22 20 Supra note 1; Supra note 3; Supra note 17 21 http://www.nhl.com/ice/playerstats.htm?season=20122013&gametype=2&team=&position=d&country=&status =&viewname=plusminus#; NHL.com refers to this statistic as PPGA (Power Play Goals Against) 22 en.wikipedia.org/wiki/karl_alzner
9 On July 10, 2013, Mr. Alzner avoided arbitration and signed a four-year contract with an average annual value of $2,800,000 after which he will become a UFA. 23 Based on Mr. Gunnarsson s significantly higher point totals over his career and platform season, as well as his better penalty killing record in his platform season, Mr. Gunnarsson can be fairly awarded a oneyear extension valued at $3,400,000. C. MARC METHOT Mr. Methot is a 28-year-old defenseman who plays for the Ottawa Senators. He was selected 168th overall by the Columbus Blue Jackets in the 2003 Draft. Though Mr. Methot has played significantly more NHL games than Mr. Gunnarsson, his main aspect of comparability is the circumstances regarding his most recent contract. Had Mr. Methot gone to arbitration, he too would have only been eligible for a one-year SPC pursuant to Article 12.9(c). As it is, Mr. Methot settled with his club prior to arbitration. Table 7: Mr. Gunnarsson and Mr. Methot Career Statistics 24 Player GP G A P P/GP PIM Carl Gunnarsson 224 12 57 69.31 58 Mark Methot 322 9 53 62.19 239 Over his career, Mr. Methot has scored 62 points over 322 games, averaging 0.19 points per game. Mr. Gunnarsson has scored 69 points over 224 games, averaging 0.31 points per game. Mr. Methot plays a rougher game and has accumulated four times as many penalty minutes as Mr. Gunnarsson, albeit in more games, with only two-thirds as many points per game. Table 8: Mr. Gunnarsson and Mr. Methot Platform Season Statistics 25 Player GP G A P P/GP PIM ATOI SHATOI Carl Gunnarsson 37 1 14 15.41 14 21:16 2:35 Marc Methot 74 0 15 15.10 58 19:53 2:56 23 Supra note 22; http://capgeek.com/player/865 24 Supra note 1; http://www.nhl.com/ice/player.htm?id=8470760#&navid=nhl-search 25 Ibid; http://www.nhl.com/ice/player.htm?id=8470760&view=splits
10 In Mr. Methot s platform season in 2010-2011, he played 74 games and notched 15 points. Mr. Gunnarsson played half as many games and had the same number of points. Similarly, Mr. Methot accumulated 58 penalty minutes during his platform season. Pro-rated over 74 games, Mr. Gunnarsson has only 28 penalty minutes less than half of Mr. Methot s. Mr. Gunnarsson also had a better showing on the penalty kill. Mr. Gunnarsson s 8 SHGA while he was on the ice in 37 games is much lower than Mr. Methot s 35 SHGA in 74 games. Mr. Gunnarsson s average is.22 SHGA per game while Mr. Methot s is more than twice that at.47 SHGA per game. On July 5th, 2011, Mr. Methot signed a four-year SPC with an average annual value of $3,000,000. 26 Compared to Mr. Methot, Mr. Gunnarsson has superior offensive statistics, lack of excessive penalty minutes, and a better penalty killing record. For these reasons, it is fair to award Mr. Gunnarsson a one-year SPC valued at $3,400,000. IV. CONCLUSION Based on an evaluation of Mr. Gunnarsson s career statistics, his platform season, and his overall contribution to his club, he respectfully submits that the arbitrator award him a one-year SPC in the amount of $3,400,000. His offensive upside over his career and platform season are similar to Mr. Quincey s and higher than Mr. Alzner s and Mr. Methot s. His defensive statistics, particularly in his platform season, characterize a responsible defenseman who does not take excessive penalties like Mr. Quincey and Mr. Methot. Further, his shorthanded statistics in his platform season exceed the performance of all three comparable players, who all play dominant shorthanded minutes on their respective clubs. For these reasons, Mr. Gunnarsson can be fairly awarded an SPC worth slightly less than Mr. Quincey and slightly more than Mr. Alzner and Mr. Methot at the mandatory one-year length with a value of $3,400,000. 26 en.wikipedia.org/wiki/marc_methot; www.capgeek.com/player/601