Commissioner Heifetz faced a routine administrative matter: editing co-host Craig Horlbeck’s roster to remove an injured player that a Yahoo platform glitch had locked into the active lineup. Rather than execute this ministerial act quietly—as commissioners do hundreds of times each season when addressing technical malfunctions—Commissioner Heifetz drafted and transmitted to the league an extraordinarily detailed explanatory memorandum. The communication detailed the technical nature of the glitch, cited precedent from the previous season involving his then-fiancée, preemptively addressed potential conflicts of interest, referenced anxieties from prior league controversies, and included editorial asides characterizing the week as “brutal” for Horlbeck.
Additionally, Commissioner Heifetz sent multiple pre-dawn text messages to co-Commissioner Kelly seeking approval for the roster edit, despite Kelly being asleep on the West Coast. Kelly describes waking Sunday morning to “like a fucking novel of text that’s like 50 texts.” Horlbeck, attempting to pack and drive home from the Bay Area, was similarly bewildered: “I’m like trying to pack up to drive home from the bay i’m like what the fuck is happening right now what is going on.”
We hold that Commissioner Heifetz’s administrative action—editing Horlbeck’s roster to address the platform glitch—was entirely proper and indeed constituted the exercise of sound commissioner discretion. But the extensive explanation was counterproductive. While transparency is generally commendable, verbose preemptive disclosure of routine administrative acts can paradoxically generate more suspicion than would have been created by competent execution and brief notification.
I
Let us begin with what Commissioner Heifetz did right. When a platform glitch prevented Horlbeck from removing an injured player from his active roster, Commissioner Heifetz used his administrative access to correct the problem. This is precisely what commissioners should do. Platform malfunctions occur regularly—players lock unexpectedly, injured reserve spots malfunction, waiver claims process incorrectly. Commissioners exist in part to address these technical issues when they arise.
We have repeatedly emphasized that commissioners must exercise their manual adjustment authority to correct platform errors that prevent managers from executing roster decisions they clearly intended to make. See In re Sunday Morning Trade Approval and Emergency Lineup Relief, 22-1107-1 (2022) (holding that “commissioners must provide emergency lineup relief when platform complications prevent execution of clearly intended roster moves”). In Eber v. Commissioner, 21-1215-1 (2021), we held that “when a platform technicality prevented a manager from making lineup changes” despite prompt notification of intent, “the commissioner must make retroactive lineup adjustments.”
Commissioner Heifetz’s roster edit falls squarely within this established framework. Horlbeck requested the change. The platform glitch prevented Horlbeck from executing it himself. Commissioner Heifetz used his administrative access to effectuate what Horlbeck clearly intended. This is textbook proper exercise of commissioner authority. Had Commissioner Heifetz simply made the edit and sent a brief note to the league—”Fixed Craig’s roster, Yahoo glitch prevented him from removing injured player”—this case would never have reached Fantasy Court.
But Commissioner Heifetz did not send a brief note.
II
Instead, Commissioner Heifetz composed what the fact summary aptly terms an “extraordinarily detailed explanatory memorandum.” The communication included multiple elements: technical explanation of the glitch; citation of precedent from the previous season involving his then-fiancée; preemptive discussion of potential conflicts of interest; references to anxieties from prior league controversies; and editorial commentary about Horlbeck’s “brutal” week.
Moreover, Commissioner Heifetz transmitted multiple pre-dawn text messages to co-Commissioner Kelly seeking approval. Kelly, residing on the West Coast, was asleep when the messages arrived. He awoke Sunday morning to discover what he describes as “like a fucking novel of text that’s like 50 texts.” This volume of communication—for a routine roster edit addressing a platform glitch—struck both Kelly and Horlbeck as excessive to the point of absurdity.
Commissioner Heifetz defends his approach by invoking what we might call the transparency-as-accountability principle. As he explained during oral argument, when a commissioner must use manual adjustment tools, the price of exercising that discretion is public disclosure and mockery—a social “toll” that managers must pay for requesting administrative assistance. His theory appears to be that extensive explanation serves dual purposes: it provides transparency that forestalls accusations of impropriety, and it extracts a social cost from the person requiring commissioner intervention that discourages frivolous requests for administrative assistance.
This theory has some merit. We have emphasized repeatedly that commissioners face heightened scrutiny when exercising administrative powers that could benefit themselves or close associates. See Andrew v. Commissioner, 24-0830-1 (2024) (holding that “commissioners occupy fiduciary positions requiring heightened obligations of good faith and fair dealing”). In In re Sunday Morning Trade Approval, we held that commissioners married to league members “face inherent conflicts that require heightened vigilance” and “must either recuse themselves from decisions affecting their spouses or bend over backwards to ensure those decisions are not tainted by the marital relationship.”
Commissioner Heifetz was editing the roster of a co-host—someone with whom he works closely and has substantial personal and professional ties. This relationship, while not rising to the level of spousal or familial connections we have addressed in other cases, creates at minimum an appearance that warrants some explanation. Commissioner Heifetz’s instinct toward transparency was sound. The execution was not.
III
The problem with Commissioner Heifetz’s approach is that excessive explanation can paradoxically suggest consciousness of guilt. When a commissioner performs a routine administrative function and responds with an extraordinarily detailed memorandum preemptively addressing conflicts of interest, citing precedent, and referencing prior controversies, the natural reaction is to wonder: what is he so worried about? Why does a simple roster edit require this level of explanation?
As the fact summary observes, league members “responded not with gratitude for transparency but with suspicion that the extensive explanation itself evidenced wrongdoing.” This is the fundamental irony of over-explanation. A brief note—”Fixed Craig’s roster per his request, Yahoo glitch”—would have generated no suspicion because the action is plainly proper. But a lengthy memorandum citing precedent and preemptively addressing conflicts transforms a non-issue into an issue. It signals that the Commissioner himself believes the situation requires extensive justification, which invites scrutiny that would otherwise never materialize.
We might call this the Goldilocks problem of commissioner disclosure. Too little transparency invites accusations of self-dealing or hidden conflicts. See Denmark Team Owner v. Commissioner, 25-0717-2 (2025) (condemning commissioner who “ignored explicit written instructions” and refused to explain systematic acquisition of players requested by absent league member). But excessive explanation paradoxically undermines its own purpose by transforming routine competence into performative anxiety.
The optimal level of disclosure for routine administrative acts lies somewhere in between: acknowledge what was done, provide brief explanation if requested, and move on. Commissioner Heifetz’s memorandum—with its citations to precedent, preemptive conflict-of-interest analysis, and references to league anxieties—reads less like transparent communication and more like a legal brief defending against charges no one has filed. It is transparency as self-sabotage.
IV
The pre-dawn text messages to co-Commissioner Kelly warrant separate discussion. Commissioner Heifetz sought Kelly’s approval before executing the roster edit, transmitting multiple messages during hours when Kelly—residing on the West Coast—was asleep. Kelly awoke to discover a “novel” of texts about a matter that did not require his approval and could easily have waited until morning or been handled with a single brief message.
We appreciate Commissioner Heifetz’s instinct to consult a co-Commissioner when making administrative decisions that could create appearances of conflict. In Andrew v. Commissioner, 24-0830-1 (2024), we established best practices recommending that “commissioners who wish to execute trades should submit them to neutral review by a league co-commissioner” to ensure “someone without a conflict evaluates the transaction.” This principle extends to administrative decisions that benefit close associates.
But consultation does not require multiple pre-dawn text messages about a routine roster edit. A single message would have sufficed: “Craig has a Yahoo glitch preventing him from removing injured player. Planning to use commissioner tools to fix it. Let me know if you see any issues.” This provides transparency and invites co-Commissioner input without generating the kind of messaging volume that transforms a non-event into a crisis.
The volume and timing of Commissioner Heifetz’s texts created exactly the problem his transparency was meant to avoid. Rather than demonstrating sound judgment and routine competence, the flurry of pre-dawn messages suggested anxiety about a decision that should have been straightforward. As Horlbeck observed, the situation felt “out of control” despite involving nothing more than a routine platform malfunction.
V
We acknowledge that Commissioner Heifetz operates in an environment where his every decision faces scrutiny. As a podcast host adjudicating fantasy disputes for public consumption, and as Commissioner of a league that includes his co-hosts, he faces a level of accountability that ordinary commissioners do not experience. His citation to precedent involving his then-fiancée suggests that past administrative decisions created controversy he wishes to avoid repeating.
But the solution to past controversies is not to transform every routine administrative act into an exercise in preemptive justification. The solution is to develop judgment about which decisions warrant extensive explanation and which do not. Editing a roster to address a platform glitch at the affected manager’s request falls firmly in the latter category. It is the fantasy football equivalent of a non-controversial ministerial function.
We return to Commissioner Heifetz’s theory that extensive explanation serves the dual purposes of transparency and extracting a social cost—mockery—from managers who require commissioner intervention. This theory fails because it misidentifies who bears the social cost in this case. The mockery here attaches not to Horlbeck for experiencing a platform glitch, but to Commissioner Heifetz for responding to that glitch with a novel-length memorandum and multiple pre-dawn texts. The “toll” was paid by the wrong person.
Moreover, the extensive communication did not actually prevent Horlbeck from requesting similar assistance in the future, nor did it generate league-wide acceptance of commissioner discretion to edit rosters. Instead, it generated exactly what Commissioner Heifetz sought to avoid: suspicion that something improper had occurred. As we have explained, this is the inevitable consequence of over-explanation. When you write a dissertation about why your obviously proper conduct was proper, people wonder why you felt the need to write the dissertation.
* * *
We emphasize that Commissioner Heifetz committed no misconduct. He performed a routine administrative function that commissioners properly perform every week of every fantasy season. He did so at Horlbeck’s request to address a legitimate platform malfunction. The roster edit itself was entirely proper and constituted exactly the kind of competent commissioner action that preserves competitive integrity when technology fails.
What Commissioner Heifetz did not do well was calibrate his explanation to match the situation. A simple roster edit did not require a detailed memorandum citing precedent and preemptively addressing conflicts of interest. It did not require multiple pre-dawn text messages to a co-Commissioner residing in a different time zone. It required, at most, a brief note to the league and perhaps a single message to the co-Commissioner: “Fixed Craig’s Yahoo glitch, moving on.”
The lesson for commissioners is this: transparency is a virtue, but judgment matters. When performing routine administrative functions at a manager’s request to address platform malfunctions, execute competently and explain briefly. Save the lengthy justifications for situations that actually warrant them—trades with family members, disputed playoff rulings, contentious veto decisions. For routine matters, the proper approach is what one host aptly termed quiet competence: do the right thing, acknowledge what you did, move on.
Commissioner Heifetz’s extensive communication defeated its own purpose by transforming a non-issue into an issue. League members responded with suspicion not because the roster edit was improper—it was plainly proper—but because the extraordinary explanation suggested the Commissioner himself believed it required extraordinary justification. It did not. It required ordinary competence and brief transparency. Next time, Commissioner Heifetz should write less and trust more in the obviousness of doing the right thing.
Commissioner’s administrative action affirmed. Verbose explanation gently mocked.