Two Swings and a Miss by NHL Department of Player Safety?

Controversy erupted after Toronto Maple Leafs goaltender Anthony Stolarz was seen vomiting on the bench during a television timeout, following two blows to the head in Game 1 of the Eastern Conference Semifinals of the NHL Playoffs.[i] The first incident occurred in the opening period, when Panthers forward Sam Reinhart fired a wrist shot that dislodged Stolarz’s face mask.[ii] The second, and most contentious, came in the second period, when Panthers forward Sam Bennett’s arm made contact with Stolarz’s head during a net-front battle.[iii] After sustaining these two hits, Stolarz left Scotiabank Arena on a stretcher in the third period and was taken to a hospital for evaluation.[iv]

Many argue that Sam Bennett’s play was intentional, calling it a “cheap shot” that warrants supplemental discipline from the NHL.[v] However, Chris Johnston reported on X that “Sam Bennett is not expected to face any supplemental discipline for his hit on Anthony Stolarz.”[vi] While Bennett’s hit was seen as the more egregious play, the question remains: who is ultimately to blame for the head injury that forced Stolarz to leave the game?

Melissa Drew Squires, MD, MPH, and Pediatric Neurocritical Care Specialist, explained: “immediate post-concussive changes in cognition, reasoning, sensory integration, balance, and emotional regulation significantly increase an athlete’s vulnerability to further injury and impair their ability to accurately assess their own condition and injury severity. Just like how we wouldn’t trust the cranky toddler who insists they’re “not sleepy.” Athletes in this state depend on their team, coaches, trainers, and medical professionals to act as fiduciaries, prioritizing the athlete’s long-term brain health over short-term performance goals. It is essential to resist tempting myopic lens on immediate victories and instead adopt a long-term perspective that safeguards cognitive function and overall well-being long after the athlete’s competitive career has ended.” Accordingly, these symptoms were likely present and should have been addressed immediately following Reinhart’s wrist shot. However, Stolarz remained in the game. Unfortunately, it took visible signs of distress such as, sustaining another blow to the head and vomiting on the bench, before he was finally removed from play.

The NHL’s decision not to further investigate Bennett’s hit on Stolarz raises questions and serious doubts. During a post-game interview, when asked about Bennett’s play, Maple Leafs head coach Craig Berube stated: “Elbow to the head, clearly. Clear as day,” and said, “I’m not sure why there’s not a call on it.”[vii]

Given these circumstances, let’s analyze the NHL and the NHLPA’s supplementary discipline section of the collective bargaining agreement (CBA) to determine whether there are inconsistencies in the decision not to suspend Sam Bennett. Since Bennett is not expected to receive supplemental discipline, the NHL likely concluded that his conduct was neither intentional nor reckless, pursuant to Rule 18.2 of the CBA.[viii] Bennett stated: “The last thing on my mind is thinking about elbowing him in the head. When it happened, I didn’t even realize I made contact.”[ix] In addition to Bennett’s statement, he and Stolarz were teammates and won the Stanley Cup together during the 2024 NHL playoffs. Therefore, Bennett makes a strong case that he lacked any intent to injure Stolarz.

Bennett; however, has a history of receiving supplemental discipline in the playoffs, which is a relevant factor in determining whether a suspension should be issued.[x] In the 2021 NHL Playoffs, Bennett received a one game suspension for boarding.[xi] In the 2022 NHL Playoffs Bennett received a three-game suspension for an illegal check to the head.[xii] Then in the 2023 NHL Playoffs Bennett concussed Leafs forward Matthew Knies without receiving suspension, and in the same game, he cross-checked then Leafs forward Michael Bunting in the head, resulting in a max fine of $5,000 but no suspension.[xiii] Most recently, in the 2024 NHL Playoffs, Bennett received no suspension for punching then Bruins forward Brad Marchand in the head.[xiv]

Sam Bennett has a history of making these types of plays, and it came as a shock to much of the hockey world when the NHL declined to further investigate. However, Bennett presented a strong case that he lacked any intent to injure his former teammate. His actions did not appear to involve the excessive or unnecessary force required to warrant supplemental discipline under the eyes of the NHL.

As this unfolds, everyone hopes that Anthony Stolarz makes a speedy recovery and can return to action as soon as possible.

[i] https://www.nhl.com/news/anthony-stolarz-injury-status-update

[ii] Id.

[iii] Id.

[iv] https://www.espn.com/nhl/story/_/id/45016228/toronto-maple-leafs-goaltender-anthony-stolarz-exits-game-1

[v] https://ftw.usatoday.com/story/sports/nhl/2025/05/06/sam-bennett-anthony-stolarz-suspension-panthers-maple-leafs/83470662007/

[vi]https://x.com/reporterchris/status/1919746836274786685?ref_src=twsrc%5Etfw%7Ctwcamp%5Etweetembed%7Ctwterm%5E1919746836274786685%7Ctwgr%5Ea4ad3a55f5f306a1299395f505eea694b5ce8b27%7Ctwcon%5Es1_c10&ref_url=https%3A%2F%2Fbleacherreport.com%2Farticles%2F25193380-maple-leafs-goalie-anthony-stolarz-reportedly-out-hospital-after-head-injury

[vii] https://thehockeynews.com/nhl/toronto-maple-leafs/latest-news/report-maple-leafs-anthony-stolarz-being-evaluated-in-hospital-after-leaving-game-1-vs-panthers

[viii] https://www.nhlpa.com/the-pa/cba

[ix] https://www.sportsnet.ca/nhl/article/panthers-bennett-comments-on-hit-on-maple-leafs-stolarz/

[x] See supra note ix

[xi] https://www.tsn.ca/nhl/sam-bennett-no-stranger-to-playoff-controversy-after-latest-incident-against-maple-leafs-1.2301456