Professional wrestling body is lying over the wrestler. This often results in pins that can easily be kicked out of, if the defensive wrestler is even slightly conscious. For example, an attacking wrestler who is half-conscious may simply drape an arm over an opponent, or a cocky wrestler may place his foot gently on the opponent's body, prompting a three-count from the referee. Illegal pinning methods include using the ropes for leverage and hooking the opponent's clothing, which are therefore popular cheating methods for heels, unless certain stipulations make such an advantage legal. Such pins as these are rarely seen by the
Victory Road (2004) rules. A Texas Death match is similar to a Last Team Standing match, however, the competitor must pin or make his opponent submit before the referee begins his count. Daniels pinned Storm following hitting him in the knee with a steel chair to begin the ten count, which Storm failed to make. Daniels was the second to be eliminated, failing to reach the ten count after being pinned following a top rope legdrop by Harris. With the outcome of the match down to the competition between Harris and Skipper, Harris hit Skipper with the Catatonic onto a steel chair. Harris