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
Nick Patrick (referee) even had a match against Earl Hebner at the WWF Invasion pay-per-view on July 22, 2001 in Cleveland, Ohio. Patrick lost to Hebner and Mick Foley, the special guest referee, gave him "Mr. Socko" after the match. During the time of the Alliance, Patrick would continue to play a heel referee, siding with the Alliance wrestlers over the WWF wrestlers. For example, during a WCW Championship handicap match between The Rock and Booker T & Shane McMahon at WWF Unforgiven 2001, Patrick would refuse to count when the Rock had Booker or Shane pinned down. At Survivor Series, Patrick knocked