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
Referee (professional wrestling) time by a move that is not considered particularly devastating when applied to a wrestler. A special guest referee is a stipulation for any match in which the usual referee is replaced with a "guest" filling in as the official. Celebrities (such as Muhammad Ali in the main event of WrestleMania I), managers and other wrestlers can "guest" as the special referee. In some cases, a special referee is put into a match which is already a different match type or stipulation (for example: Hell in a Cell with a special referee). The special referee would often be biased towards