2003 YMCA Mock Trial

Declaration of Jessie St. Laurent

I, Jessie St. Laurent, hereby declare as follows:

My true name is Jessie St. Laurent. I am 50 years old. I am a stockbroker by profession. I work at Citibank Investors Group in Denver, Colorado.

I have been a licensed United States Soccer Federation (USSF) referee for 14 years. Currently I hold a Grade 4 license. I work both men’s and women’s games at the college, semi-professional, amateur and youth levels. With my next upgrade to Grade 3, I will be qualified to officiate professional games. I have been selected four times to officiate the final four of the Men’s NAIA College Soccer Cup (1998, 1999, 2000 and 2001), three times to officiate the Women’s NCAA Division I Southwest Regional, and two times to officiate the Men’s NCAA Division I Final Four. I have been the Director of Referee Licensing and Instruction for the Region IV Referee Association for the past six years. Region IV includes 12 western states, including Washington, Oregon and California. I have also been a member of the national referee discipline committee for the past five years. On this committee we hear and decide misconduct complaints against referees, appeals of referees who are denied promotion, and other matters involving referee licensing, referee fitness, and game-related referee conduct.

I was invited to be an observer at the Washington State Cup by the Washington State Referees Association and was asked to participate in a referee symposium on player safety, sportsmanship and proposed revisions to the Laws of the Game. During the symposium I met all the referees assigned to the senior age groups at the State Cup (U-16 through U-19).

The rules of soccer are unique in their simplicity. They have not changed much in 100 years. Seventeen “Laws of the Game” govern all aspects of the game from the size and dimensions of the field and air pressure of the ball to the rules of play and player discipline. Management of the game and interpretation of the rules are left largely to the sole discretion of the lead official, i.e., the “referee” of the match. The referee is assisted by two “assistant referees” (often called “linesmen” or “ARs”) who are stationed on either side of the field and who are primarily responsible for calling “off side” violations and ruling when the ball has gone out of bounds (i.e., when the ball is “in touch”). In college and professional games, there is a “fourth official” who manages conduct and behavior on the team benches and coordinates player substitutions.

I watched all four championship games that day (U-16, U-17, U-18 and U-19). In the U-18 game it was obvious from the start that Referee Kyle Dennis was going to have his hands full with the No. 18 player from FC Ignition and the No. 2 player from FC Red Dog. They started in on each other as soon as the game began. Garrison (#18) was marking Chavez (#2) very tight and took him/her down with a hard, late slide tackle in the opening minutes of the game. I say “hard” because Garrison made no attempt to avoid body-to-body contact as s/he slid through the ball. The tackle was late because Chavez had beaten Garrison, and the tackle came from a 45-degree angle from behind. Luckily for Garrison, s/he caught part of the ball before s/he upended Chavez or the referee might have shown him/her a yellow card right then. Referee Dennis did talk to Garrison as play continued and I saw Dennis make a hand gesture for Garrison to calm down.

Chavez was very vocal and challenged the referee for his failure to show the yellow card to Garrison. I thought the referee showed extraordinary restraint in not showing the yellow card to Chavez. Chavez was right in his face. But Dennis is an experienced referee. S/he talked to Chavez and kept a close eye on both of them. But Chavez would not let up. Chavez challenged every call Dennis made for the entire first half.

Chavez made a lot of blatant, ticky-tack fouls during the first half. It looked like s/he was daring Dennis to show him/her the yellow. S/he pulled opponents’ jerseys, pushed and shoved opponents, taunted them, and clipped their heels every chance s/he got. And Chavez and Garrison kept up this constant verbal war for the entire first half.

Garrison made a couple more hard tackles in the first half. Garrison was, obviously, not as fast as Chavez and it seemed like Chavez knew exactly how Garrison was going to defend his/her every move. Chavez is a gifted dribbler and adeptly sidestepped most of Garrison’s tackles. For most of the first half, Garrison was chasing Chavez. On several occasions Chavez made him/her look real bad, and Chavez let him/her know it. I heard Chavez use the word “schooled” many times. That term is a taunting comment used by player who uses his superior skill to beat another player. It means, “I just showed you up.” In that instance, the beaten player is said to have been “schooled” by the other player. On the third or fourth hard slide tackle, Garrison clipped Chavez’s heel before contacting the ball, and Dennis showed him/her the yellow card. Garrison did not seem to care.

Just before halftime it was starting to get out of control, and Dennis cautioned Chavez (showed him/her the yellow card) for his persistent infractions. S/he probably could have booked him/her for dissent also. The referee had his choice. Chavez should have been booked sooner, in my opinion. As the teams left the field at halftime, the referee talked to both players, but I could not make out what s/he said.

In the second half, Chavez and Garrison played with more restraint for the most part. Garrison continued to play hard, physical defense, but s/he stayed on his/her feet and only used the slide tackle on one occasion. It was a clean tackle. But Chavez was getting the best of him/her, and it was only a matter of time before Chavez scored a goal. S/he had three break-away chances in the middle of the second half and made three brilliant shots that just missed the mark. The second one hit the cross bar.

In the final minutes of the game, I think it was around the 80^th minute, Chavez received a pass and beat Garrison down the left flank with a brilliant hesitation dribble move. Garrison was beaten and instinctively, it seemed, made a slide tackle to knock the ball out of bounds. But Chavez made him/her miss, and Garrison slid out of bounds then bounced up and started chasing Chavez. Chavez cut to his/her right and headed straight for the sweeper who was positioned between Chavez and the goal. Chavez slowed down to measure the movements of the sweeper then megged him/her (dribbled the ball between the sweepers spread-apart legs).

Before the sweeper could straighten up and recover, Chavez took a lightening quick shot on goal from just outside the penalty area in the “D” (the quarter circle that is in the shape of a “D” at the top of the penalty area). This area is sometimes called the penalty arc. While he/she was still in a follow-through position, Garrison came flying in from behind and on Chavez’s left side and made a wild, airborne slide tackle with his/her cleats up that was much too late. S/he contacted Chavez on the outside of the left knee and everyone in the stadium heard the multiple pops of the knee being shattered. It was sickening.

Garrison was way out of line with that tackle. It had no possible chance of success. The ball was all the way to the goal before Garrison made contact with Chavez. There was no possible excuse for that play.

I was astounded to see Garrison jump up and start yelling over Chavez’s crumpled body. I thought I saw Garrison kick Chavez while Chavez was writhing on the ground before his/her teammate and the referee stepped in to grab him/her. Chavez’s teammate also stepped in. Then the crowd of players gathered and it was a confusing scene. It all happened very fast. I was shocked.

Referee Dennis immediately stepped in and showed Garrison a red card. But Garrison refused to leave the field. S/he was out of control, yelling and gesturing at Chavez. Garrison’s teammate tried to restrain him/her but it took an assistant coach and a couple other team members to forcibly get him/her off the field. I have no clue what caused his/her eruption.

The game was delayed for about 15 minutes while the medics attended to Chavez, who was writhing in pain and screaming. Once s/he was loaded into the aid car the game continued but without much heart or enthusiasm. FC Red Dog missed the direct kick to restart play and both teams exchanged turnovers for the next few minutes. Finally, with only 1 or 2 minutes left, FC Ignition scored on a corner kick and the game ended 1-0.

The Laws of the Game make player safety the number one responsibility of the match referee. I suppose Dennis could have ejected Garrison earlier for one of his/her late tackles from behind, but that is sheer speculation. Law 12 prohibits the use of recklessness or excessive force, and several of Garrison’s earlier slide tackles could have been characterized as reckless. The last one was extremely reckless at the very least. It is absolutely unacceptable to slide tackle with your cleats up. It is also unacceptable to slide tackle from behind. Finally, the tackle was made so late it would be reasonable to conclude that it was intentional. But I do not know what Garrison was thinking at the time and I do not want to jeopardize his/her future by speculating on his/her intent.

Soccer is a very intense competition. There are no time-outs in soccer, and the clock never stops ticking. Unlike basketball and football players do not have time to cool down after every play. So, when tempers flare, things happen very quickly.

I do not fault Dennis for trying to allow these two good players to remain in the championship game. For his overall game management, I give Dennis a “B minus” grade or a high “C+.” That’s pretty good under the circumstances. This was a tough assignment.

I have examined the field diagram created by the prosecutor and agree with his/her positioning of the players, coaches, referees and spectators, including me.

I am available to discuss the Laws of the Game and their interpretation at any time. Just call my office.

I HEREBY DECLARE UNDER PENALTIES OF PERJURY UNDER THE LAWS OF WASHINGTON THAT THE FOREGOING IS TRUE AND CORRECT.

Dated this 20^th day of June, 2002.

/s/ Jessie St. Laurent

______________________________

Jessie St. Laurent