The NFL’s First Replay Controversy

The following article originally appeared on I’ve moved it here to consolidate all Dayton Triangles-related content on this site.

The research for my Dayton Triangles podcast project took me into the period when Triangles player/coach/manager/owner Carl Storck continued to serve as an NFL executive after the sale of the Triangle franchise. This post discusses the first of two major controversies in Storck’s brief, stormy tenure as league president. My focus here is less on Storck’s role than on the historical significance of what I argue was “the birth of replay” — eighty years ago.

Time was running down at the Polo Grounds on December 3, 1939. The Washington Redskins and New York Giants were locked in a nail-biter. With a berth in the NFL Championship game on the line, the Giants clung to a 9-7 lead, but Washington was driving. With under a minute to go, the Redskins’ drive stalled at the New York 16-yard line. Kicker Torrance “Bo” Russell lined up for a relative chip-shot field goal to give Washington a 10-9 lead and probably the win. The snap came back, and Russell struck the ball. It sailed high toward the right upright as thousands of fans held their collective breath.

Referee Bill Halloran had the call. A well-respected veteran of gridiron officiating going all the way back to pre-NFL sandlot days, Halloran always called them as he saw them. This time, some observers thought he hesitated ever so slightly, while others thought he did not hesitate at all. Halloran waved his arms at his waist, a gesture known at the time as a “wigwag,” signifying that the attempt was no good. New York ran out the clock to win the game, and the division championship.

The game was over, but the controversy had just begun.

Many observers insisted the kick was actually good. Others insisted just as vehemently that it was well wide to the right. The angle from which the observer viewed the kick had a lot to do with the conclusion drawn. (One’s rooting interest may have played a role, too.)

After the game, fans, writers and photographers looked for visual evidence to either confirm or overrule Halloran’s call. Unfortunately, the available evidence was not very helpful. First, Russell’s kick had sent the ball so high that it might not appear in the photo frames of many shots. (Note 1.) The photo evidence that showed the ball suffered from the same disadvantage as human observers; depending on the camera angle, the ball appeared to be inside or outside the uprights. (Note 2.)

Sportswriter Gene Ward reviewed film of the kick taken at an angle behind the kicker and to right of the goal post. In his opinion, the visual evidence was not conclusive that the ball had actually passed inside the uprights. (Note 3.)

In the language of modern replay officiating, it was a “call stands.”

Part of the problem may have been a misunderstanding about the rules. In the modern NFL, a field goal is “good” if it is ” between the goal posts and above the cross bar, or, if above the goal posts, between the outside edges of the goal posts.” (Note 4.) [Emphasis added.] In 1939, though, you didn’t get the benefit of the outside edge of the goal posts if the ball was above them. Some players, coaches or fans may have thought getting any part of the ball over the upright was sufficient for the kick to be good. It wasn’t.

Dr. B. A. O’Hara, a league official in attendance but not in the officiating crew that day, explained to sportswriter Dan Parker:

The officials of the National League were called to Pittsburgh before the season opened for a rules interpretation meeting. Stress was laid on field goal kicking and it was drilled into us that in professional football all parts of the ball must be inside the plane made by the imaginary lines drawn straight up into the air as an extension of the goal posts.

Parker, Dan. “Dan Parker Says”. Courier-Post (Camden, New Jersey), Dec. 5, 1939, p. 20

In the weeks after the game, proposals surfaced to assist the on-field official. One idea, similar to horse racing’s “photo finish,” would use a set of synchronized cameras to photograph the ball from different angles. In the event of a review, the film could be developed on the spot to determine if the kick was good. (Note 5.) Another proposal would use an electric eye to automatically rule whether the kick was good or not. (Note 6.)

None of the 1939 proposals gained traction, and it would be decades before the NFL instituted a replay rule, but Bill Halloran’s “wigwag” set events in motion that eventually led to the modern replay regime.

And what of Halloran’s infamous call?

Harry Dayhoff, a college referee who had worked the Holy Cross-Boston College game the day before, was sitting with sportswriter Dan Parker and NFL official Dr. O’Hara behind the opposite end zone — at the perfect angle to judge the kick’s accuracy. After the kick, and before Halloran’s signal, Dayhoff said, “It’s wide, Doc.” O’Hara agreed, adding that in his view no part of the ball was in that imaginary plane required for a good kick. (Note 7.)

And on the field, holder Frank Filchock turned his back to the play and disgustedly snapped his fingers. (Note 8.)


(1) “Pictures May Not Help”. Philadelphia Inquirer, December 4, 1939, p. 23.

(2) Hartford Courant, December 6, 1939, p. 13.

(3) Ward, Gene. “Redskin Faces Ban For Life, Plus Fine”. New York Daily News, December 5, 1939, p. 352.

(4) Goodell, Roger, Commissioner. 2018 Official Playing Rules of the National Football League.

(5) “Foto-finish In Football”. New York Daily News, December 12, 1939, p. 37.

(6) United Press. “Plan Electric Eye To Rule On Field Goals”. The Morning Call (Allentown, Pennsylvania), December 19, 1939, p. 7.

(7) Parker, Dan. “Dan Parker Says”. Courier-Post (Camden, New Jersey), Dec. 5, 1939, p. 20

(8) Menton, Paul. “Important Points”.The Evening Sun (Baltimore, Maryland), December 7, 1939, p. 44.

By Bruce Smith

Writer, producer and host of the podcast "Triangles: The Life and Times of an NFL Original Team." Music composer and producer. Dayton, Ohio native.