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
Hell in a Cell (2012) unaffected and performed a Meat Hook Clothesline on Punk. Ryback attempted Shellshocked but the referee Brad Maddox inexplicably stopped Ryback and attacked him with a low-blow. Punk pinned Ryback with a roll-up as Maddox made a fast count, thus Punk retaining the title. After the match, Maddox attempted to escape from the cell but was attacked by Ryback. After chasing Heyman, Punk attempted to escape by climbing the cell but Ryback followed him and executed Shellshocked atop the cell. Maddox explained on "Raw" that he had intentionally cost Ryback the match as a way of making a name for himself