On October 19, 2024, the Texas Longhorns played Southeastern Conference (SEC) college football rival the Georgia Bulldogs in a matchup that will go down in history. History for what you might ask? Not because Georgia beat Texas in some memorable fashion, but because the Texas student section reacted after the referees called a controversial penalty in the game.[1] The penalty the refs called? A pass interference penalty during the game which nullified Texas’s interception of Georgia’s quarterback. This interception (in the moment) would have been a game changer for the Longhorns, who were losing to the Bulldogs by 23-8. Outraged by the pass interference call, the Longhorn student section booed and threw trash on the field in disgust.[2] Students in the section threw bottles and other various trash onto the field, stopping play and giving the officials time to review the penalty. In response to the fans’ behavior, Texas head coach Steve Sarkisian went to the endzone where the fan section belongs and told them to stop throwing bottles.[3] While Sarkisian empathized with Longhorn fans’ frustration, he condemned their behavior while essentially telling them to be better.[4]
Given the opportunity to review the penalty, the refs overturned the call, awarding the Longhorn’s the interception and a huge chance to bring the game within one possession.[5] The question the SEC now faces – did the student section’s unwarranted behavior help the Longhorns and cause the refs to overturn the pass interference penalty? Some suggest it does. More than anyone, the Bulldog’s head coach Kirby Smart stated after the game that “[n]ow we’ve set a precedent that if you throw a bunch of stuff on the field and endanger athletes that you’ve got a chance to get your call reversed.”[6] However, the SEC did not accept this claim, stating that the reaction from fans did not persuade their decision to overturn the call. Rather, the referee team discussed the play within their own discretion and was free from influence.[7] Texas was fined $250,000 dollars by the SEC in response to their fans throwing the trash onto the field. The SEC explained their fine was for “interrupting the competitive opportunity for both teams and endangering contest participants.”[8] Further, Texas must “use all available resources – including security, stadium and television video – to identify those who threw trash onto the field or at the Bulldogs – and prohibit them from attending Texas athletics events for the remainder of the academic year.”[9]
Can the conference require the Longhorn students who threw trash on the field to be banned from attending athletic events for the rest of the year? Subject to Texas University’s Code of Conduct, the school provides that Texas Athletics is committed to providing a safe and enjoyable environment for all.[10] Specifically, the relevant portions of the Code of Conduct require fans to:
- Support our teams in a positive manner while treating visiting fans, teams and officials with dignity and respect.
- Promote an environment that minimizes disruption, creates a safe atmosphere for all, prevents interference with the game and ensures the enjoyment of the game for everyone.
- Refrain from using foul or abusive language or inappropriate gestures or attire.
- Be responsible when consuming alcoholic beverages. Impairment, intoxication, underage consumption and unruly behavior will be address immediately.[11]
Further, the Code of Conduct carves out a sportsmanship policy to regulate fan behavior while attending Texas Athletics. The sportsmanship policy reiterates the need for athletes, spectators, and officials, to value a safe environment that is free from disorderly behavior.[12] Moreover, “[a]ny spectators creating an unsafe environment or who interferes with the game… will be removed from the facility.”[13]
It is presumed that throwing bottles and trash onto the field during a Longhorn Football game qualifies as a violation of Texas’ Code of Conduct. But, the Code of Conduct makes no mention of a year-long ban from attending sporting events. Other than ejection from the Texas game, is a year-long taking this too far? Can the conference subject these students to discipline or require the school to do so for them? If so, the SEC will need to be uniform in their punishment as the effects of the Longhorn fans bottle throwing has spread across the conference. Only one week after the Longhorns game, Ohio State fans threw trash on the field. In their game against the Nebraska Huskers, Ohio’s linebacker Arvell Reese broke up a pass attempt by the Husker’s, but was called for targeting, which the fans did not agree with. After the play was upheld on review, the Buckeye fans threw trash, bottles, and food on the field. [14] So is the Longhorn fans behavior a new norm for fans when they are upset with the officiating? Probably not. But, it will be interesting to see if this trend continues and how the SEC handles thousands of students misconduct at football games.
[1] Hayden Victoria, McConaughey scolds ‘Not Cool’ Texas student section for bottle throwing, Longhorns Wire (Oct. 22, 2024) https://longhornswire.usatoday.com/2024/10/22/mcconaughey-scolds-texas-students-bottles/.
[2] Dave Wilson, Texas fined $250k, apologies to Georgia, officials for fan behavior, ESPN (Oct. 20, 2024) https://www.espn.com/college-football/story/_/id/41904999/texas-apologizes-georgia-officials-sec-fan-behavior.
[3] Id.
[4] Id. (Further, the school stated that “While we deeply appreciate the passion and loyalty of our fan base at The University of Texas at Austin, we do not condone the unsportsmanlike conduct that was exhibited by some individuals throwing objects onto the field during last night’s game and sincerely apologize to the University of Georgia players, coaches, and fans, as well as the Southeastern Conference and officiating crew…”).
[5] Id.
[6] Id.
[7] Ryan Morik, Texas fined $250,000 for fans throwing debris on field, ‘required’ to find those who did so, Fox Sports (Oct. 21, 2024) https://www.foxnews.com/sports/texas-fined-250000-fans-throwing-debris-field-required-find-those-who-did-so.
[8] Wilson, surpra note 2.
[9] Id.
[10] Football Fan Guide – Code of Conduct, Texas University, https://texaslonghorns.com/sports/2013/7/29/GEN_0729133817#:~:text=Sportsmanship%20Policy,be%20removed%20from%20the%20facility.
[11] Id.
[12] See Sportsmanship Policy in Texas University Code of Conduct, https://texaslonghorns.com/sports/2013/7/29/GEN_0729133817#:~:text=Sportsmanship%20Policy,be%20removed%20from%20the%20facility.
[13] Id.
[14] Chris Landers, It’s spreading: Ohio State fans followed Texas’ lead by flinging bottles onto the field after controversial call, Fansided (Oct. 26, 2024) https://fansided.com/it-s-spreading-ohio-state-fans-followed-texas-lead-by-flinging-bottles-onto-the-field-after-controversial-call.
[15] Texas fined $250,000 for fans throwing debris on field, ‘required’ to find those who did so | Fox News.
Alex Brockhuizen (’25) is pursuing her JD at the University at Buffalo School of Law, with a concentration in Sports Law. After graduation, she will be working at Bond, Schoeneck & King PLLC. At UB, Alex is co-director of the Labor and Employment Law Society and Treasurer of the Buffalo Sports Law and Entertainment Law Society. She is also Business Editor of the Buffalo Law Review, where she was deemed a finalist of the Note and Comment Competition her 2L year. Alex is also a former two-sport athlete at Elmira College.
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