UFC 148: Could Chael Sonnen Win a Potential Athletic Commission Appeal?

Jonathan Snowden@JESnowdenCombat Sports Senior WriterJuly 9, 2012

TUALATIN, OR - JUNE 26:  (Editor's Note: This image was converted to black and white.)  Sonnen prepares to conduct a workout at the Team Quest gym on June 26, 2012 in Tualatin, Oregon.  Sonnen will fight Anderson Silva July 7, 2012 at UFC 148 in Las Vegas, Nevada.  (Photo by Jonathan Ferrey/Getty Images)
Jonathan Ferrey/Getty Images

Chael Sonnen's coach Scott McQuarry shocked the MMA world when he announced that he intended to file an appeal with the Nevada Athletic Commission on Sonnen's behalf.

McQuarry believes that a bout-changing Anderson Silva knee, a blow that struck a seated Sonnen and took the fight out of him, was in violation of Nevada rules.

The coach has since decided to focus his attention on a public relations campaign to get Sonnen a third fight with the long-time champion, contending Silva violated several rules and that Sonnen didn't get a chance to compete in a fair contest. 

But, had he continued forward, could Sonnen or his team have won a potential appeal. I reached out to Nevada Athletic Commission Executive Director Keith Kizer who believes there wasn't a case for Sonnen.

"(There are a) very limited grounds for appeal," Kizer wrote. "I do not see where this would fit."

Kizer pointed me toward the Nevada regulations, which stipulate three reasons a decision might be overturned. Let's analyze each and see if Sonnen has a case. 


1.  The Commission determines that there was collusion affecting the result of the contest or exhibition.

This would be an explosive allegation if true, but no one is making this claim. Although boxing bouts were commonly fixed into the 1950s, when the mafia ran the sport, we've never seen any accusations of fight fixing in modern mixed martial arts. 

In the era before Zuffa's reign, however, accusations of fight fixing were not unknown. The most famous example is Oleg Taktarov's 12-second submission win over stablemate Anthony Macias. Both were managed by Buddy Albin, who allegedly asked Macias to take the fall. I recounted the story in my book Total MMA:

"I was in on the conversation with Anthony Macias, Oleg, and Buddy," former UFC fighter Andy Anderson said. Everyone knew that Oleg was going to need every ounce of strength he had to beat the Tank."

Chance of a Sonnen appeal winning on these grounds? None.

2. The compilation of the scorecards of the judges discloses an error which shows that the decision was given to the wrong unarmed combatant

This has actually happened in the UFC this year. Demetrious Johnson was awarded a decision over Ian McCall, only to find out backstage that a judge's scorecard had been incorrectly reported. The fight was then ruled a draw. The two had a rematch later in the year that Johnson won without further incident.

Chance of a Sonnen appeal winning on these grounds? None.

3. As the result of an error in interpreting a provision of this chapter, the referee has rendered an incorrect decision.

Kizer told McQuarry that this was the provision he might possibly use in an appeal. He could make a case that referee Yves Lavigne misunderstood a provision in the rules that disallows a knee strike or a kick to the head of a downed opponent. McQuarry or Sonnen could argue that the thigh is part of the leg, making Silva's collision with Chael after his knee to the sternum an illegal blow.

The problem here is that there's significant debate about whether or not Silva's leg struck Sonnen and whether or not the contact was incidental. If it's unclear after watching numerous replays and extreme slow motion clips, it will be difficult for the commission to decide that the referee was in error. He made a call that was reasonable at the time and remains so in retrospect.

Chance of a Sonnen appeal winning on these grounds? Slim.

The only other way for a decision to be over turned would be for Silva to fail a post-fight urinalysis. That, based on Silva's career and character, seems unlikely. 


Good Chael is wise RT @missADelgado: @mmaencyclopedia @MMAjunkieDannGentlemen: Chael says there is "no appeal."

— Matt Lindland (@mattlindland) July 9, 2012


All things considered, I agree with Sonnen's former coach Matt Lindland, who says Chael would be wise not to appeal this loss. While McQuarry has valid points, the best place to present them is either privately to the UFC or in the court of public opinion. Just keep it far, far away from a court of law.