No Foul – No Ban; A Soccer Referee – Player Incident

May 19, 2023

By John T. Wendt, J.D., M.A., Professor Emeritus, Ethics and Business Law, University of St. Thomas

Premier League Soccer in England may be the best in the world, with the best players, managers, stadiums, revenue, and overall depth and competitiveness.[1] Concurrently, the Premier League referees are supposed to be the best in the world, and many expect them to be calm, controlled, and infallible. One commentator described being a referee in the Premier League an “impossible job” with constant complaints from players, fans, and know-it-all’s.[2] Darren England, a Premier League referee said, “People don’t expect a striker to score every time they shoot, but for us every decision needs to be correct…No one notices the things referees do right, but everyone remembers the errors.”[3]

There have been numerous articles regarding abuse of soccer referees, including instances of referees in various sports and levels being attacked by players and fans.[4] During a grassroots soccer game, a London official, Satyam Toki, was punched three times in the face above his left eye and suffered a blackout. The perpetrator was banned for five years.[5] At a Cumberland County League a player berated a referee with vulgarity, pushed the referee’s chest three times and twice punched and struck the referee in the back of the head. That perpetrator was banned from all soccer activities for seven and a half years.[6] Many organizations have launched “No Ref – No Game, Red Card to Ref Abuse” campaigns.[7][8] The English Football Association (FA) also announced an “Enough is Enough” campaign addressing unacceptable behavior in soccer.[9]

On the Premier League level, Fulham striker Aleksandar Mitrović was given an eight-game ban for pushing referee Chris Kavanagh during a game with Manchester United. The FA reported that an Independent Regulatory Commission issued a three-match ban for violent conduct against Mitrović in addition to the three-match ban he had already received for the red card offense and an additional two-match ban. Mitrović immediately apologized saying, “I allowed my frustration to get the better of me, and how I reacted was wrong. I was trying to get the referee’s attention, but I appreciate that I should not have put my hands on him and I understand why he showed me a red card, my first in-game sending off for Fulham and my first since the 2015/16 season.”[10]

On a much smaller scale there have been relatively few cases where a referee attacked a player.  On August 2, 2023, during a Liga MX game between Club América and León, Mexican referee Fernando Hernandez was preparing to give a yellow card to Leon midfielder Lucas Romero.  Hernandez apologized saying, “To the fans and public in general, I offer an apology, as well as to Romero, for my reaction…I would never attack him or any other player. I am aware of this and I will abide by the decision of the Disciplinary Commission.”[11] Later Romero said that it was a misunderstanding, “Obviously [referees] are human beings, many times they can make mistakes and those mistakes end up developing what happened, a lot of misunderstandings…”[12] The Federación Mexicana de Fútbol Asociación (FMF) suspended the referee for 12 games for violating Article 30 paragraph (g) of the FMF Sanctions Regulations, by engaging in violent conduct against a player.[13]

In all the previous cases the actions were intentional. What happens if the player-referee incidents were accidental? 

This was the case during a game on April 9, 2023 between Arsenal and Liverpool involving Premier League Official, Constantine Hatzidakis, and Andy Robertson of Liverpool.  At the end of the first half of the game, video replays appeared to show Hatzidakis throwing up his arm and making contact with Robertson. Robertson motioned and argued that Hatzidakis had hit him.  Immediately after the game the Professional Game Match Officials Limited (PGMOL) issued a statement saying, “PGMOL is aware of an incident involving assistant referee Constantine Hatzidakis and Liverpool defender Andrew Robertson at halftime during the Liverpool v. Arsenal fixture at Anfield…We will review the matter in full once the game has concluded.”[14]

After the statement, there was an uproar in the media calling for immediate action, including bans. Former Manchester United captain Gary Neville said, “I’ve never seen an official raise an elbow to a player…I think he’ll [Hatzidakis] be in a lot of trouble after this game ends.”[15] While another former Manchester United captain, Roy Keane said, “Does Robertson grab the linesman first? I’m not sure but Robertson’s then complaining…He [Robertson] should be more worried about his defending…”[16] Even former Premier League referee Keith Hackett commented that “Ultimately, if he [Hatzidakis] is found guilty of this, his career is in jeopardy…He is an employed official, so employment law cuts in, but I’m calling in saying the ban on Mitrovic wasn’t long enough so hey, this has got to be the equivalent, if he is found guilty.”[17]

On April 9, 2023, PGMOL issued a statement saying, “PGMOL will not be appointing Constantine Hatzidakis to fixtures in any of the competition it serves whilst the FA investigates the incident involving the assistant referee and Liverpool defender Andrew Robertson at Anfield.”[18]

With both sides arguing, the question remains: what should be done? The FA could issue a ban on both the referee and the player – ban Robertson to satisfy those who think he initiated the contact and at the same time ban Hatzidakis to satisfy those who are angered against him. Could there be litigation for assault? But what would that accomplish? Fortunately, cooler heads prevailed.

A very short time later, on April 13, 2023, there was a decision (compare that time frame with most litigation). A FA statement read, “We have thoroughly reviewed all of the evidence in relation to the recent incident at Anfield involving the Liverpool defender Andrew Robertson and match official Constantine Hatzidakis, and we will be taking no further action…Our comprehensive process involved reviewing detailed statements from Liverpool and PGMOL (Professional Game Match Officials Ltd), as well as multiple angles of video footage, in relation to both the incident and its surrounding circumstances.”[19]

The PGMOL also revealed that Hatzidakis said, “I fully assisted the FA with their investigation and have discussed the matter directly with Andy Robertson during an open and positive conversation. It was certainly not my intention to make any contact with Andy as I pulled my arm away from him and for that I have apologized (sic). I look forward to returning to officiating matches.”[20] Not only did Robertson accept the apology, but it was reported that his team, Liverpool, was impressed with how Hatzidakis handled the matter and appreciated the leadership by PGMOL’s chief refereeing officer Howard Webb.[21]

So, what is there to learn from this incident? Martin Cassidy, the chief executive officer of Ref Support UK, called for rules that only captains can speak to officials. He also proposed an “Exclusion Zone” of about one or two meters (or yards) around referees to stop players from getting too close. Cassidy said, “All of these situations are happening when a player makes contact with a referee. It has been going on for years…Let’s create an exclusion zone where if you go that close to a match official you get a card no matter what. That might make the game a bit less aggressive and more productive.”[22]

One of the best lessons learned from this is the need for calm. Just as not every injury warrants a lawsuit, not every incident needs an immediate ban. There was a thorough and fast investigation.  There were sincere apologies and reconciliation. There was dispute resolution and both sides put the incident behind them and moved forward. That was the best result for all.

[1] Swindon Link, Top reasons why Premier League is the best in the world, (2022), (last visited Apr 27, 2023).  See also Chuck Booth, World Cup 2022 by the numbers: Premier League leads the way, Bayern Munich top represented club team, (2022), (last visited Apr 27, 2023). Mark Carey, The global game — analysing international imports in Europe’s top five leagues, (2023), (last visited Apr 27, 2023).  Gab Marcotti, Why the Premier League’s success goes deeper than its star power, competitiveness or upsets – ESPN, (2022), (last visited Apr 27, 2023).

[2] William Ralston, The impossible job: inside the world of Premier League referees, The Guardian, Mar. 21, 2023, (last visited Apr 27, 2023).

[3] Id.

[4] Celena Dell, Misia Gervis & Daniel J.A. Rhind, Factors influencing soccer referee’s intentions to quit the game, 17 Soccer & Society 109 (2016).  See also Paul Downward, Tom Webb & Peter Dawson, Referee Abuse, Intention to Quit, and Well-Being, 0 Research Quarterly for Exercise and Sport 1 (2023). 

[5] SkySports, Referee protection urged as assaults at grass roots level revealed by support charity, Sky Sports (2021), (last visited Apr 27, 2023).

[6] Paul MacInnes, ‘Matter of time’: experts warn of risks to referees amid epidemic of abuse, The Guardian, Oct. 22, 2022, (last visited Apr 27, 2023).

[7] Mai Lee, No Ref No Game Keep Supporting REFspect, Don’t X The Line (2022), (last visited Apr 27, 2023).

[8] Football Association of Ireland, Respect for Referees in focus with #NoRefNoGame, (2022), (last visited Apr 27, 2023).

[9] The Football Association, Enough is enough, (2022), (last visited Apr 27, 2023).

[10] Sammy Mncwabe & Amy Woodyatt, Fulham striker Aleksandar Mitrović gets eight-game ban for pushing referee, (2023), (last visited Apr 27, 2023).

[11] BBC Sport, Mexican referee gets 12-match ban for kneeing player, BBC Sport, Apr. 4, 2023, (last visited Apr 27, 2023).

[12] Id.

[13] Sergio Mancilla, Referee Fernando Hernández hit with 12-game ban for kneeing player, Diario AS (2023), (last visited Apr 27, 2023).

[14] AP News, Referees body to review clash between official and Robertson, AP NEWS (2023), (last visited May 1, 2023).  All refereeing appointments in the English Football League are handled by Professional Game Match Officials Limited (PGMOL).[14] 

[15] Pa Sport Staff, Refereeing body to investigate Andy Robertson being ‘elbowed’ by linesman, The Independent (2023), (last visited May 1, 2023).

[16] Id.

[17] BBC Sport, Constantine Hatzidakis: “His career is in jeopardy,” BBC Sport (2023), (last visited May 1, 2023).

[18] Jonathan Johnson, Premier League ref Constantine Hatzidakis faces investigation for apparent elbow on Liverpool’s Andy Robertson, (2023), (last visited May 1, 2023).

[19] The Guardian, Assistant referee Hatzidakis cleared over elbow incident at Liverpool, The Guardian, Apr. 13, 2023, (last visited May 1, 2023).

[20] Id.

[21] Id.

[22] Matthew Henry, Hatzidakis “punished enough” for Robertson incident, BBC Sport, Apr. 11, 2023, (last visited May 1, 2023).

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