Gobitis(1940) [Later overturned] West Virginia State Board of Education v. Barnette(1943) Texas v. Johnson(1989) United States v. Under the rules protecting defenseless players, it does not matter where the primary point of contact is. Even if Burfict hit Sherman initially and primarily in the chest, he cannot also make contact to the head or neck. Also, it doesn’t matter what Burfict intended, under the rules.
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