In a Washington Post article discussing this issue from a couple years back with John Adams, the NCAA coordinator of basketball officiating it was said to be a foul "If a ballhandler is swinging his elbows as part of a full-body movement and at the same speed as the rest of his body at the time of contact, an intentional foul is to be assessed, giving the opponent two free throws and possession of the ball." In 2011 the terminology was changed to Flagrant 1 for this type of foul with the ruling stating "An example of a Flagrant 1 foul would be a player who swings an elbow and makes non-excessive contact with an opponent above the shoulders. The team whose player was struck would receive two free throws and possession of the ball." Wolfe did not swing his arms at all just brought them up. It did not meet the criteria of a Flagrant 1 foul which is the weaker of the two types of Flagrant fouls.