In 1977, Super Bowl Coach Chuck Noll was sued for $2 million for slander for calling Oakland Raider George Atkinson part of a “criminal element” in football: Has the criminal element moved to Cleveland?

George Atkinson hitting Lynn Swann

[This was not the infamous 1976 hit.]

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… showed how dirty Oakland — and others — in the league were

It was a spectacle so bizarre, so beyond the realm of common sense and ordinary imagination that it might have been the creation of some mad comic producer—a cross, say, between Mel Brooks and the Marquis de Sade. But there it was: in the clean well-lighted environs of a U.S. district courtroom in San Francisco the National Football League, that most august and shining symbol of American morality, excellence and all-round exemplary life style, was on display with a full line of dirty laundry. The subject was mayhem, and judge and jury listened with fascination as all manner of lurid language was applied to the grand old game—"wanton violence," "gang warfare," "criminal acts," "happiness at pain," "love of blood."

William Oscar Johnson, Sports Illustrated, 1977

Football fans of all stripes are outraged by the actions of Cleveland Browns Myles Garrett in slugging Pittsburgh Steeler quarterback Mason Rudolph with his helmet on Thursday night in Cleveland.

However, this was not the first time that the Steelers have been victimized by a cheap shot artist. The last time was 43 years ago, and things became so intense that Steeler Coach Chuck Noll, winner of Super Bowls in 1975 and 76, complained about a “criminal element” in football.

The result was a lawsuit by the cheap-shot artist, George Atkinson, who alleged that Noll had defamed his reputation with his comments. Defamation requires that a person’s reputation be damaged, and Atkinson alleged that his had been and sued for $2 million in damages.

The case

A Sports Illustrated story gave the genesis of the issue, along with a detailed analysis of the trial itself,

How did this all come to pass? The genesis occurred late in the first half of the first game of the 1976 season, on the afternoon of Sept. 12, when the Raiders and Steelers met in Oakland. Lynn Swann, the splendid wide receiver of the Steelers, ran a pattern down the right side of the field, then cut to the middle. He was covered by George Atkinson, a tough but hitherto unheralded defensive back for the Raiders. As the play unwound, Terry Bradshaw was forced to scramble, eventually firing a pass to Franco Harris, who thundered downfield. As Harris caught the ball, some 15 yards away Atkinson rushed up behind the unsuspecting Swann and cracked him with a forearm at the base of the helmet. Swann dropped as if he were shot. He suffered a concussion and missed the next two games. No official saw Atkinson's blow, no penalty was levied.

William Oscar Johnson, “A walk on the sordid side,” 

Sports Illustrated, Aug. 1, 1977

The video of the cheap shot is available at this URL [you have to copy and paste it]:

https://www.youtube.com/watch?v=gxzKlHc_xsk

Swann suffered a concussion on the play, and Steeler Coach Chuck Noll was outraged. So much so that a day later, he lambasted Atkinson and the Raiders,

The day after the game Noll rose before a luncheon press conference in Pittsburgh and spoke coldly of "a criminal element" in the NFL. He said that players like Atkinson should be "kicked out of the league." The game had been the first nationally televised contest of the season and had drawn a huge audience; the NFL office was swamped with calls and letters about Atkinson's hit.

Johnson, SI, Aug. 1, 1977

Will Roger Goodell respond as Pete Rozelle did?

After viewing film of the incident, Commissioner Pete Rozelle sent a letter to Atkinson that read in part,

In sixteen years in this office I do not recall a more flagrant foul than your clubbing the back of Swann's head totally away from the play.... Our sport obviously involves intense physical contact, but it requires of all players discipline and control and remaining within the rules. Every player deserves protection from the kind of unnecessary roughness that could end his career.

Johnson, SI, Aug. 1, 1977

Suffice it to say that Goodell is no Pete Rozelle, the man who established the NFL as the financial powerhouse that it is today. While Garrett has been suspended for the rest of the season, clubbing someone with a helmet is a dangerous escalation of violence in what is one of the most violent sports in history.

Rozelle admonished Noll, which outraged Rooney

However, while Rozelle basically sided with the Steelers in the trial since he thought that the entire league was on trial, he still was upset with Noll’s characterization of others in the league,

Rozelle sent another letter to Noll concerning his remarks about the NFL's "criminal element." He pointed out that Noll had violated a constitutional bylaw of the league by publicly criticizing another team or player. The commissioner fined the coach $1,000.

Johnson, SI, Aug. 1, 1977

However, Dan Rooney, then the CEO and president of the Steelers, was upset with the fine. He charged that the Raiders had intended to harm Swann, who was one of the premiere receivers in the league,

This letter drew an angry reply from Dan Rooney, president of the Steelers. He charged there had been "direct, premeditated, unemotional efforts by the Oakland Raiders to seriously injure Lynn Swann" and went on to say, "I believe it is a cowardly act to hit someone from behind with his back turned. I also believe, because of the number of Oakland Raider players making such attacks on Lynn, the Raiders must have an opinion that Lynn is vulnerable and can be forced out of the game, which makes such acts premeditated and involves the Raiders' coaching staff as well as the players." Rooney sent along a film clip to prove exactly how brutal the Raiders had been in their assaults on Swann.

Johnson, SI, Aug. 1, 1977

The trial

In a short blog, I cannot do justice to the trial, but Johnson’s SI pieces goes into great detail and is worth a read. When the ten-day trial had ended, the jury sided with Noll and said that because there was no malice, there could be no defamation, no slander.

The lead lawyer for Noll and the Steelers was a top California defense attorney, James Martin MacInniss, and the SI piece points out that in his closing,

MacInnis then noted that the Oakland crowd had cheered when Atkinson struck Swann, and the attorney said, "I think that's a sad commentary on the motives of our generation.... It's sadistic, this secret love of violence, the spectacle of liking to see others hurt, happiness at pain, enthralled by the love of blood. That's the America of George Atkinson."

Johnson, SI, Aug. 1, 1977

NFL hardly has an “august” reputation today

While Johnson talked about the reputation of the National Football League being sterling, that is hardly the case today. It is much wealthier, but many problems from criminal actions by players to the physical damage being done to players by concussions have hurts its cred.

Actions like Garrett took illustrate that the criminal element in the NFL — and the Raiders were pre-eminent in that area at that time despite the words of their quarterback at that time, Kenny Stabler, that everyone does it — is still alive and well.

It has just moved a few thousand miles east.

Noll was confronted by Atkinson lawyers who charged that some of his own players could be considered to be criminal in their behavior. They noted actions by Mean Joe Greene and Mel Blount, who subsequently became members of the NFL Hall of Fame, along with Glen Edwards, a hard-hitting defensive back.

However, hard-hitting and criminal are very different. The current defense is hard-hitting, and while there are probably no future hall of famers on it, there are no criminals either.

The Steelers center Maurkice Pouncey has received a three-game suspension too for protecting his quarterback against Garrett but he pummeled him with punches. Is he part of the criminal element? Are the Browns are bad as the Raiders were in the 1970s?

Stay tuned. This could get interesting.

Read the SI piece from 1977

Copy and paste the URL:

https://www.si.com/vault/1977/08/01/621920/a-walk-on-the-sordid-side