Case Study: Illegal GK Touch Infraction Leads to Goal

Case Study # 22-2013
Match Date 12 July 2013
Competition Major League Soccer
Fixture/Result PHI 2 – 1 CHV
Referee/Badge Jorge Gonzalez, USSF Grade 3
At Issue The referee awarded an indirect free kick to Philadelphia after deciding the Chivas USA goalkeeper illegally touched the ball (a so-called “pass back” violation)

In the 79th minute of the match, a cross was played into the Chivas USA (red) penalty area by a Philadelphia attacher.  The Chivas USA goalkeeper attempted to collect the cross, but lost possession, resulting in the ball moving straight toward the top of the penalty area.  A Chivas USA defender who was moving toward his own goal made contact with the ball with his foot, and the ball was next touched by the Chivas GK with his hands.  The referee immediately whistled for an illegal GK touch foul.  The ensuing indirect free kick resulted in a goal for Philadelphia.

Do you agree with the decision?

Paul Rejer of PRO (the Professional Referees Organization) says “no”:

Law 12 states that: ‘An indirect free-kick is awarded to the opposing team if a goalkeeper, inside his own penalty area, touches the ball with his hands after it has been deliberately kicked to him by a teammate’. The key word here is deliberate, that is what the referee has to decide.

In this play it is obvious that this was not a deliberate pass as the ball rebounded to the keeper from a challenge and not a contrived pass.

Mr. Rejer arrives at his conclusion that the kick by the Chivas defender is “obvious[ly]…not a deliberate pass” because “the ball rebounded to the keeper from a challenge and not a contrived pass”.

We need to parse Mr. Rejer’s statement in order to better understand his position.

“The ball rebounded to the keeper from a challenge”

The word “rebound” is found neither in the Laws of the Game nor in the Advice to Referees in the context of an illegal GK touch.  The Merriam-Webster dictionary defines “rebound” as “to spring back on or as if on collision or impact with another body”.  I don’t believe the use of the word “rebound” adds to the understanding or analysis of this incident.  It’s at best confusing and at worst misleading.

“not a contrived pass”

Another term not found in any official publication, “contrived” is defined as “having an unnatural or false appearance or quality”.   In Mr. Rejer’s defense, I have to assume he misuses the word “contrived”, and actually means the opposite.  Antonyms of “contrived” include “natural” and “unforced”.  I would submit that there is an even better word to use in this case: deliberate.  If you’ll allow me a bit of artistic license, I’ll rewrite Mr. Rejer’s statement, substituting the definitions of the these two words for the words themselves:

In this play it is obvious that this was not a deliberate pass as the the ball sprang back to the goalkeeper after impact with the Chivas defender’s foot and not from a deliberate pass.

In other words this was obviously not a deliberate pass because it wasn’t a deliberate pass.  That’s not a very compelling argument, in my opinion.

I mean no disrespect to Mr. Rejer.  I am sure he knows much more about refereeing that I ever will.  However, I would humbly ask him to choose his words very carefully, as they are being read by thousands of referees all over the country.

To get back to the heart of the matter, let’s return to the Advice to Referees and use a very helpful tool provided to help make decisions in this case: The Test of the Triangle.

ATR Test of the Triangle

One last trip to the dictionary provides us the definition of “deliberate”.  Definition #2 defines it as “characterized by awareness of the consequences”.  So, we ask ourselves, does a professional soccer player realize that kicking the ball with his foot while under pressure from an attacker could lead to an infraction if the goalkeeper next touches the ball with his hands?

What is “obvious” to this observer is that the three sides of the triangle are present and accounted for: the defender deliberately kicks the ball which is then touched by the GK with his hands.  The referee’s decision was fully in keeping with the Laws of the Game.

If that isn’t the desired outcome, IFAB need to provide new guidance to referees.  Let’s not criticize referees for making decisions fully in keeping with the LOTG , the ATRs and the Interpretations.



9 responses to “Case Study: Illegal GK Touch Infraction Leads to Goal”

  1. Contrived also means “obviously planned or forced; artificial; strained”. The player did not obvious plan the direction of the kick into the general vicinity of the goal keeper. I would argue that the awkward method of taking the kick and spin on the ball demonstrate a lack of planned or deliberate kick. If the definition of deliberate is “aware of consequences”, then any play where a defender attempts to cleared the ball and it happens to bounces to a keeper could be classified as a pass back. I would also argue that the spirit of the law comes into play. My understand is that the spirit of Law 12 is to prevent trick plays and delay tactics. This spirit did not seem to apply in this instance.


    • Chris, I completely agree with you in terms of the Spirit of the Game (and thanks also for the clarity on the definition of ‘contrived’). My problem is that the Advice to Referees is crystal clear in this regard. I would like to see the Laws/Interpretations changed to give us some more latitude in this regard. But based on my reading of the ATRs, we have little.


  2. I answered the Referee’s decision was correct based on SOP and AOV. I had a similar play and decision in a U16B Silver Elite match. It was nearly an identical play. I had better AOV than the the Referee here: the defender’s own approach angle sends up the red flag that he’s about to attempt to pass to the keeper. His teammates were even screaming at him “NO!” How can this not be deliberate? It cannot. In this Case Study’s situation, from the Referee’s AOV, and at SOP, the defender’s direction to get the ball is such that he has no choice BUT to pass it to the GK. Even the replay seems to suggest it; watch the GK’s hesitation in his own decision to put his hands out to collect the ball from his teammate, there’s a hitch in his movements. The body language is there to take care of “deliberate” the rest is academic, all there and obvious.

    Anyway, I do wonder about PRO’s judgment in the response and the misuse of language within it. It isn’t the first time they’ve decided differently from the Referee’s judgment decision made at SOP. It’s troubling and feels a little political—I notice the few times, that I can recall off the cuff, they’ve come down against their own Referee’s judgment call there was a send-off involved at some point in the process of making the call, or the result of it—league/economic impact influencing perceptions/motives? It has happened in professional and amateur sports alike though most would very like like to deny it or frame it alternately. It’s an intuition; I don’t really know if this is in fact the case here. I don’t know if sensory input is even possible to affirm or conflict with that intuition, given the potentially controversial nature of it for some parties.

    As a working referee, it’s difficult to know what to make of the opinion other than its secondary authority and perhaps could be considered indirect secondary since it’s PRO and not USSF directly (as in a Memo, Directive, or Position Paper). I wouldn’t feel comfortable applying Mr. Rejer’s opinion because I’m just not convinced yet. (If it becomes direct secondary authority via USSF, that’s different, of course).

    Great Case Study. Got me thinking.


  3. The triangle must be referenced in context. What’s most important is the entirety of the phrase “deliberately kicked to him”. With this in mind, you can’t read the triangle on its own and have to accept that “to him” is understood and implicit.


    • The Law does not require that the ball be kicked to the keeper. The Law says that the ball must be deliberately kicked (ie, not a deflection), and that the keeper then handles the ball. The intent of the kicker should never cross your mind. The triangle says it all. Three words: 1) Deliberate 2) Kick 3) Handles.

      I agree with the comment above, if this is not how the powers that be want it interpreted, then change the Law and ATR. Until then, the call is simple, give the IDFK.


  4. The defender was looking directly at the GK before he kicked the ball. The finesse of the kick also supports a deliberate pass to GK. From the way the defender fell, he could have kicked harder across the goal line, but didn’t. The GK made the mistake of handling the ball instead of kicking to the side.


  5. the defending player did not pass the ball back. as seen in the video, the ball goes in a random direction because of the challenge for it. no way to know where its going and i dont see any hesitation on the keepers part in picking it up. whats sad here is the yellow (2nd) / red card being issued. could have been avoided!!! down a player and scored against. the ref influenced the game and thats ashame!


  6. I suggest reading ATR 2013 12.20. “deliberately kicked” means that the play on the ball is deliberate and does not include situations in which the ball has been, in the opinion of the referee, accidentally deflected or misdirected.

    This a fairly clear definition when combined with other definitions in this section.

    Then look Back at minute 1:01 and you just might see that red kicked the ball and it deflected from the defender as he attempted to play it. Given the difference in angle of the referee one can hope that he saw something different. However, given the pace of play and the flight path of the ball it is very hard to see intent by the defender.


  7. From the view on the video it is possible that the ball went off the defenders shin, if so then definitely not a violation – I also believe that if it was off his foot still no violation, the ball was at best miskicked (look at the spin and it also looks like he tried to swipe at it with his right foot and missed). I see no deliberate kick to the keeper.


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