The Enforcement Problem HISA Can’t Outsource Away

May 27, 2026

Two enforcement failures. Two different arms of HISA’s regulatory apparatus. One week.

Neither failure is a close call. Neither involves disputed science, ambiguous evidence, or a genuinely difficult judgment. Both involve something more troubling: a regulatory authority that has built its enforcement model around outsourced decision-making and is now absorbing the consequences of what happens when those it relies upon get it wrong.

Past The Wire has been on both stories. This piece connects them.

The Lopez Ruling: What The Footage Shows

On May 16, Paco Lopez won the Preakness Stakes aboard Napoleon Solo. In the stretch, from approximately the three-sixteenths pole to the wire, Lopez raised his wrist above his helmet before striking his mount on three separate occasions. Past The Wire reviewed the broadcast footage — head-on and pan — multiple times. The images are not ambiguous.

HISA Rule 2280(c)(1) is explicit. A rider may not raise the crop with the rider’s wrist above the rider’s helmet when using the crop. One standard. No qualifications. No exceptions for riding style. The wrist is either above the helmet or it is not.

The Maryland Racing Commission stewards reviewed the same footage and found no violation. Administrative steward Adam Campola offered a single explanation to the press: Lopez has an unorthodox style, stays busy on a horse. The number of strikes, four, below the six-strike limit, was not in question. The question was wrist position relative to helmet, and the stewards determined there was no violation.

No written finding was published. No frame-by-frame analysis was released. No explanation of how publicly circulated stills reviewed independently by multiple journalists including this publication were evaluated and dismissed. The stewards said they didn’t see it. The public record of how they reached that conclusion does not exist.

The stewards’ finding does not change what the footage shows. It changes only what the official record says happened.

HISA, which had announced an investigation following prior reporting on the matter, deferred entirely to the stewards. The authority said it found “no basis on which to assert before an appeals panel that it is ‘clearly erroneous’ or ‘not supported by the evidence.'” HISA said it would not comment further.

This is not an isolated incident for Lopez. He received HISA’s most significant whip violation penalty in September 2025, a six-month suspension he effectively never served, riding through the suspension period in Louisiana while HISA counted those months as time served due to ongoing federal litigation. Past The Wire raised this at HISA’s April 21 Town Hall and received the same answer twice: litigation prevented action, months counted as served. Our follow-up, why not count from Lopez’s return to HISA tracks, received no public answer.

Lopez returned to HISA tracks April 1. He won the Preakness on May 16. The stewards have now determined, without a published finding, that what the footage shows is not what happened.

The Dunn Case: When the Foundation Collapses

On May 27, 2025, exactly one year before this piece publishes, investigators from the Pennsylvania State Horse Racing Commission conducted a barn search at Parx Racing, targeting trainer Felissa Dunn. They reported finding syringes without needles on a window sill and in a tack room. HIWU subsequently tested residue from those syringes and alleged traces of Chlorpromazine and Propionylpromazine, both antipsychotic sedatives classified as banned substances.

What followed was a career-ending charge against a trainer with a spotless record. Zero positive tests in her entire career. A potential lifetime ban, built on the statements of two state investigators who had signed written documentation establishing the chain of custody.

On May 6, 2026, HIWU learned that one of those investigators intended to change their testimony under oath. The investigator admitted that two investigators, not one, had actually been involved in the search and seizure. The sworn written statements had been false. The chain of custody they established was materially inaccurate.

On May 19, 2026, HIWU withdrew all charges against Felissa Dunn.

HISA CEO Lisa Lazarus issued a statement that did not minimize what had occurred. She announced that HISA and HIWU would no longer accept the participation of the investigators involved in any HISA or HIWU-related cases. “Integrity is one of the foundational pillars of HISA’s mission,” Lazarus said, “and we have no tolerance” for what transpired. That response was appropriate and it was swift.

But the statement, however appropriate, cannot answer the question that every trainer currently facing a HIWU charge is now asking: how many other cases rest on investigator statements that have not yet been tested under oath?

A woman with a spotless career was six months from a lifetime ban. The evidence beneath it was fabricated.

The Through Line

These are not two unrelated stories that happened to occur in the same week. They share an architecture.

HISA’s enforcement model, on both the stewardship side and the anti-doping side, is built on a foundation of outsourced authority. Track stewards make rulings on riding crop violations; HISA reviews and defers. State investigators conduct barn searches and execute chain of custody; HIWU relies on their sworn statements. The assumption embedded in both structures is that the people HISA outsources to will perform their functions with competence and integrity.

In the same week, both assumptions failed.

The stewards produced a finding that contradicts footage reviewable by any person with access to the broadcast replay. HIWU built a career-ending case on investigator statements that were fundamentally compromised. In neither case did HISA’s structure include an independent verification layer capable of catching the failure before it became a public record.

In the Lopez matter, the failure remains on the books. The ruling stands. HISA accepted it.

In the Dunn matter, the failure surfaced only because a witness was unwilling to commit perjury on the stand. The case collapsed on the eve of arbitration. Dunn’s attorney Drew Mollica and the arbitration process, not HISA’s internal mechanisms are what ultimately protected her.

Lisa Lazarus has been, by any measure, more willing to engage publicly and directly on difficult issues than virtually any other executive in this industry. Her response to the Dunn collapse was serious and her removal of the investigators was the correct call. Past The Wire acknowledges both.

But acknowledgment of good faith at the leadership level does not resolve the structural question. HISA’s credibility as a federal regulatory authority ultimately rests not on the integrity of its CEO but on the integrity of the enforcement apparatus she oversees. That apparatus has now failed publicly on two fronts in one week, in cases with radically different facts but the same underlying design flaw.

What Comes Next

PETA has called for a Maryland Racing Commission inquiry into the Lopez stewards’ ruling. Whether the MRC acts will be its own answer. Past The Wire will report on it if and when it comes. I’m betting against.

The Dunn dismissal raises a question HISA has not yet addressed publicly: a comprehensive review of active HIWU cases that relied on statements from the removed investigators, and what, if anything, HISA intends to do about them.

The rule Lopez was found not to have violated, Rule 2280(c)(1) is in need of clearer drafting. If the rule’s language creates room for the interpretation the stewards applied, that is a separate problem requiring a separate fix.

These are not accusations of bad faith. They are structural observations about a regulatory model that has been tested and has shown where it is vulnerable. The industry deserves an honest accounting of both.

Past The Wire will continue to provide one.

Related coverage: The Stewards Looked At The Tape — And Said They Didn’t See It | Lopez Wins Preakness — And Appears To Have Done It Breaking The Same Rule That Got Him Suspended | A Seat at the HISA Table — And Questions That Deserve Answers

Yeah…..

Contributing Authors

Jonathan "Jon" Stettin

Jonathan “Jon” Stettin is the founder and publisher of Past the Wire and one of horse racing’s most respected professional handicappers, known industry-wide as the...

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