By Yan Gioseffi, PhD
On August 20, 2025, widespread violence erupted during the second leg of the Copa Sudamericana Round of 16 between Argentina’s Club Atlético Independiente (Independiente), and Club Universidad de Chile. The incident occurred inside Estadio Libertadores de América, in Argentina, resulting in chaos among supporters from both teams (Romero, 2025).
According to Fardin (2025), reports are that the conflict began when visiting fans, positioned on the upper sections of the stands, and home supporters in an adjacent area exchanged projectiles. The situation escalated as a group of Independiente fans breached the barrier separating the sections and attacked Chilean supporters. The confrontation left dozens injured, including a fan who jumped from the upper deck while attempting to escape (Nascimento, 2025).
Following an expedited disciplinary review, CONMEBOL (the South American Football Confederation) announced on September 4th, 2025, a set of administrative sanctions that included the disqualification of Club Atlético Independiente from the tournament, allowing Universidad de Chile to advance to the quarterfinals.
Administrative Sanctions and Legal Precedent
CONMEBOL (2025) published on its website the following sanctions for each club:
For Club Atlético Independiente, the sanctions were based on articles 8.1, 8.2, 12.1, and 12.2 of its Disciplinary Code, article 22 of its Safety Regulations Code, and article 5.1.11 of its Clubs Manual:
- Disqualify Club Atlético Independiente from the current competition, without exclusion from future ones.
- No fan allowance (play behind closed doors) for the next seven home matches of any CONMEBOL tournament.
- No fan allowance when playing as a visitor for the next seven home matches of any CONMEBOL tournament.
- A total of $250,000 fine to be debited from income from TV rights and sponsorships.
For Club Universidad de Chile, the sanctions were based on articles 8.1, 12.2, 15.2, and 27 of its Disciplinary Code,
- No fan allowance (play behind closed doors) for the next seven home matches of any CONMEBOL tournament.
- No fan allowance when playing as a visitor for the next seven home matches of any CONMEBOL tournament.
- A total of $270,000 fine to be debited from income from TV rights and sponsorships.
For both teams, additional sanctions included:
- To display a poster with the phrase “Stop Racism, Discrimination, and Violence”.
- A strict limit on the number of personnel allowed in the games to be played behind closed doors.
The disciplinary code of the CONMEBOL has very similar doctrines to those suggested by FIFA (International Federation of Association Football) and the UEFA (Union of European Football Associations); clubs are strictly responsible for the conduct of their supporters – strict liability principles. As exemplified in this case, misconduct of fans directly affects clubs regardless of their intent or fault (Kleef, 2016). In practice, this means that even if a club cooperates with authorities or condemns the violence, liability remains absolute. This case reinforces the precedent that severe fan violence can result in full disqualification, not merely fines or closed-door sanctions.
Historically, using fines and warnings as administrative sanctions are common, but full expulsions are rare. After extensive research, only one other case of exclusion in CONMEBOL tournaments was identified, which classifies this sanction as one of the toughest disciplinary decisions. The last comparable decision occurred in 2015, when Argentina’s Club Atlético Boca Juniors was expelled from the Copa Libertadores after fans attacked their rival’s players with pepper spray during a Round of 16 match (Bonn, 2015). After that incident, the match was suspended, Boca Juniors expelled, and the opposing team advanced into the next round. Another major incident—the 2018 Copa Libertadores final—forced CONMEBOL to relocate the River Plate vs. Boca Juniors final to Spain due to violent clashes between rival supporters (Fernandez, 2018).
Potential Causes and Risk Factors
This case and disciplinary actions underscore several key legal risks for sporting teams relating to crowd control, fan behavior, and preventive actions that must be taken to increase the protection of stakeholders within sporting events. The Independiente incident exposes persistent vulnerabilities in South American football security systems. Contributing factors for this episode likely included:
- Weak coordination among clubs, law enforcement, and local authorities.
- Inadequate stadium surveillance and emergency response capabilities.
- Inconsistent enforcement of bans on violent supporters.
Recommendations for Compliance and Risk Management
From a legal and governance standpoint, the case underscores that fan violence equates to organizational liability (Swenson, 2012). Additionally, victims of stadium violence may pursue civil litigation against clubs or venue operators, while prosecutors may seek criminal negligence charges where safety standards are demonstrably breached. Within this case, preventive compliance and stadium safety management strategies include:
- A risk management plan focused on fan behavior must be doable, approved and enforced by governing bodies.
- Clear insurance and contractual compliance to avoid exclusion clauses when negligence is proven.
- Enhance surveillance technologies – digital ticketing and proper electronic security may help identify rowdy fans.
- Cross-sector coordination among clubs, law enforcement, and insurers to mitigate civil and criminal exposure.
- Modernized stadium design improving segregation and evacuation routes..
- Strict enforcement of fan bans through national and international cooperation.
Conclusion
The Independiente case highlights a recurring problem in South American soccer—fan violence within CONMEBOL competitions—that continues to damage the organization’s reputation. CONMEBOL’s sanctions in this case signal an effort to curb such misconduct through stricter enforcement and heightened accountability. However, questions remain about whether the current disciplinary framework and codes of conduct are achieving their intended goals. If they are not, further reform may be necessary to effectively deter future incidents.
From a broader perspective, fan safety is a fundamental expectation for all stakeholders in sport. When that safety is compromised, legal consequences often follow. Beyond the legal dimension, unsafe stadium environments can also have significant financial repercussions (Sarigul, 2020). Diminished fan attendance reduces revenue from ticket sales, concessions, and merchandise, while tournament disqualifications result in lost prize money, broadcast income, and sponsorship opportunities—financial losses that can far exceed the cost of regulatory fines.
Citation
Bonn, K. (2015, May 17). Boca Juniors expelled from the Copa Libertadores for pepper-spray incident, will appeal. NBC Sports. https://www.nbcsports.com/soccer/news/boca-juniors-expelled-from-the-copa-libertadores-for-pepper-spray-incident-will-appeal
CONMEBOL. (2025, September 4th). Decisión de la Comisión Disciplinaria. CONMEBOL. https://www.conmebol.com/unidaddisciplinaria/decision-de-la-comision-disciplinaria5/?utm_source=chatgpt.com
Fernandez, M. (2018, November 29). Final da Libertadores entre River Plate e Boca Juniors será dia 9 no estádio do Real Madrid. Globo Esporte. https://www.ge.globo.com/futebol/libertadores/noticia/river-plate-e-boca-juniors-decidem-a-libertadores-no-dia-9-de-dezembro-em-madri.ghtml
Kleef, R. H. Cvan. (2016). Liability of football clubs for supporters’ misconduct. A study into the interaction between disciplinary regulations of sports organisations and civil law (Doctoral dissertation, Leiden University). Eleven International Publishing.
Nascimento, J. (2025, August 25). Independiente bane 25 torcedores por briga com organizada da La U. CNN Esportes. https://www.cnnbrasil.com.br/esportes/futebol/futebol-internacional/independiente-bane-25-torcedores-por-briga-com-organizada-da-la-u/
Romero, P. (2025, November 04). Conmebol toma trascendental decisión en la Copa Sudamericana: Independiente es expulsado tras enfrentamientos de hinchas. El Tiempo. https://www.eltiempo.com/deportes/futbol-internacional/conmebol-toma-trascendental-decision-en-la-copa-sudamericana-independiente-es-expulsado-tras-enfrentamiento-de-hinchas-3487945
Sarigul, M. (2020). Effect of fan misconduct on the brand image of football clubs. [Master’s thesis, Erasmus University Rotterdam]. Erasmus University Thesis Repository.
Swenson, S. (2012). Unsportsmanlike Conduct: The Duty Placed on Stadium Owners to Protect Against Fan Violence to Protect Against Fan Violence. Marquette Sports Law Review, 23(1), 135-153.
Dr. Yan Gioseffi is an Assistant Professor at the College of Idaho. He is originally from Brazil and moved to the United States to study and play collegiate soccer. Throughout his journey, he found himself in academia, where he mentors and teaches students from all over the world. He holds an M.B.A. from Boise State University and a Ph.D. in Sport Administration from the University of New Mexico. His research areas include risk management, sport law, collegiate athletics, international sports, ethics, and marketing.
