Commissioned Ignorance: Rising UFC Star Kept Out of the United States by State Athletic Commissions

[1]

On October 26, 2024, in Etihad Arena, Abu Dhabi, Sharabutdin (Shara) Magomedov improved his record to 15-0 in professional mixed martial arts with a highlight reel knockout of veteran Armen Petrosyan.[2]  Nicknamed “Shara Bullet,” Magomedov had a banner year in 2024: his winning punch on Petrosyan was nominated for the 2024 Knockout of the Year award at the MMA Award Show, and his record in the Ultimate Fighting Championship (UFC) improved to 4-0.[3] While he recently suffered his first loss to British superstar Michael “Venom” Page in a competitive decision, Magomedov is still a budding superstar in the UFC.[4] Though he fell out of the top 15 middleweights in the UFC rankings after his loss to Page, he is still ranked as a top 20 middleweight in the world by Tapology.[5]

Despite his emergence onto the global MMA scene, Shara has only fought in the Middle East, where the UFC hosts around five events per year.[6] He has never competed in the United States, where the UFC is based and holds over a third of their events every year.[7] It is worth noting, that many Russian and Muslim fighters like Shara chose to fight in the Middle East due to the increased support in that area.[8] However, Shara is a different case entirely: the individual state athletic commissions will likely not allow him to fight in any state because Shara is blind in one eye.[9]

Injured during a training session in Thailand, Shara went through three years of surgery and recovery before eventually losing his ability to see out of his right eye altogether.[10] Shara was 4-0 in MMA competition at the time of his injury, and since returning in 2021, he went 11-0 in almost four years of action.[11] Despite being barred from fighting in the United States, Shara remains one of the UFC’s most globally popular rising stars.[12]

What are the State Athletic Commissions, and how do they affect the UFC?

The commission in every state is meant to standardize the rules of MMA, both to preclude the organizations from liability, as well as ensure that a dangerous industry like combat sports is as safe and fair as possible.[13] This commission’s role includes setting fighter regulations, enforcing mandatory medical suspensions based on injuries sustained, and providing licensed judges and referees for all contests within the state.[14] Essentially, the role of the commission is to ensure that no fighter has an unfair advantage and that all fighters can defend themselves against their agreed-upon opponents.[15]

The UFC itself follows the Unified Rules of MMA for combat regulations, which is followed by all of the individual state commissions, but each still has individual fighter requirements before anybody enters the ring.[16] For example, in one of the most unique instances of commission regulation, the Nevada State Athletic Commission initially banned former UFC fighter Wanderlei Silva in 2014 from competition for life for evading, but not failing, drug testing before his fight against Chael Sonnen, as well as fining him $70,000.[17] However, a federal district court judge overruled this decision, citing this being an overstepping of the commission’s statutory authority.[18] The commission, on a rehearing after the decision, reduced Silva’s ban to a three-year suspension and retracted the fine, reasoning that Silva had not been paid to fight and so the commission had no right to fine him for his fight purse.[19] So, while these state commissions do have broad authority to facilitate fair competition in combat sports within their borders, their authority is limited in this regard.

The Commission's Role and Precedent

Going back to Shara, while it is not outrightly stated by any commission that a fighter without eyesight in one eye can compete in MMA competition, there are clues to suggest that it is. Dana White, the CEO and president of the UFC, has said Shara “probably” will be unable to fight in the United States, explaining that the UFC will continue to only schedule Shara to compete in events overseas.[20] Shara’s impairment is not one unique to him, as Michael “The Count” Bisping suffered a similar injury in his 2013 fight against Vitor Belfort, almost completely losing sight in his right eye.[21] Bisping continued to fight 11 times in the United States in the next five years before retiring in late 2018 but has detailed that he wore a glass eye and dark glasses to “hide from the commission,” as he assumed revealing his injuries would lead to all state athletic commissions in the United States not allowing him to compete.[22]

Referees and doctors in MMA competitions are instructed by all states to stop a fight if any damage to an athlete’s eye renders them unable to see out of it or could cause permanent damage to it.[23] This occurred most recently in the final fight of 2024 when Joaquin Buckley cut the top of Colby Covington’s eyebrow with a punch, leaving a cut that left Covington unable to see out of the eye.[24] Despite the fight being competitive up until that point, a doctor stepped in and declared Covington unable to continue due to his inability to see out of one eye.[25] Therefore, while it is unsaid, it can be safely assumed that Shara’s eye injuries are preventing him from being able to compete in the United States.

Is This an Overstep of Authority?

The purpose of the State Athletic Commission is to ensure safe competition for all fighters, but not allowing Shara to fight in the United States because of his eye condition does not further this mission. Shara’s physical deformity is not significant enough to prevent him competing in “fair” MMA bouts. [26] Zion Clark, a former Paralympic gold medalist, fights in a professional MMA organization in California-he is able to compete in professional MMA in the United States despite being born without legs.[27] As he does not have legs, Clark is not allowed to be kicked or kneed in the head, as per the Unified Rules of Mixed Martial Arts that nearly all major MMA organizations follow.[28] Unlike this limitation, which affects the contest in a major way, I would argue that the lack of vision in an eye, especially if it is a permanent condition, is not an insurmountable limitation.

As discussed previously, Michael Bisping, despite never having competed in a championship fight before his injury, won two UFC championship fights during the time that he hid his injury from the commission.[29] Shara is now 4-1 in the most competitive MMA organization in the world and should be able to be sanctioned in any state, regardless of eyesight. If it is determined that he is not fit for competition based on fairness and ability to defend himself, then all of his prior opponents should be subject to that same declaration, as they are less able to defend themselves than Shara is. While the state athletic commissions do have a role in regulating fair competition, if a fighter is determined to be a top 20 fighter in his weight class in the world, there should be little objection from non-fighters that he is unable to defend himself, regardless of the optics involved with allowing a one-eyed fighter to compete in combat sports.

Chas Phillips (staff writer) is a 1L at Villanova University Charles Widger School of Law. His interests include intellectual property, contract negotiations, and employment law. His ultimate goal is to work in the landscape of college sports, either for a university or the NCAA.

References:

[1] Etihad Arena, Yas Island, Abu Dhabi | Joe Andr3ws | Flickr

[2] Shara Magomedov vs. Armen Petrosyan, UFC 308: MMA bout Tapology, https://www.tapology.com/fightcenter/bouts/911319-ufc-308-shara-bullet-magomedov-vs-armen-superman-petrosyan (last visited Feb 15, 2025)

[3] Id.

[4] Prospect to watch: Shara Magomedov UFC, https://www.ufc.com/news/prospect-watch-shara-magomedov-ufc-308-topuria-vs-holloway-abu-dhabi (last visited Feb 15, 2025)

[5] The current best MMA middleweights: 185 lbs.: Tapology MMA rankings Tapology, https://www.tapology.com/rankings/current-top-ten-middleweight-mma-fighters-185-pounds (last visited Feb 17, 2025)

[6] Full list of UFC venues by country (UFC event locations) GroundedMMA, https://groundedmma.com/full-list-of-ufc-venues/ (last visited Feb 15, 2025)

[7]Id.

[8] Dana White reveals Shara Magomedov “probably” can’t fight in the US despite callout from undefeated phenom Bloody Elbow, https://bloodyelbow.com/2024/06/23/dana-white-reveals-shara-magomedov-probably-cant-fight-in-the-us-despite-callout-from-undefeated-phenom/ (last visited Feb 15, 2025)

[9] Dana White reveals Shara Magomedov “probably” can’t fight in the US despite callout from undefeated phenom Bloody Elbow, https://bloodyelbow.com/2024/06/23/dana-white-reveals-shara-magomedov-probably-cant-fight-in-the-us-despite-callout-from-undefeated-phenom/ (last visited Feb 15, 2025)

[10] How one-eyed UFC saudi arabia star Shara Magomedov lost eye after 8 operations The US Sun, https://www.the-sun.com/sport/9382635/sharabutdin-magomedov-eye-how-he-lost-ufc-294/ (last visited Feb 15, 2025)

[11] Id.

[12]  Prospect to watch: Shara Magomedov UFC, https://www.ufc.com/news/prospect-watch-shara-magomedov-ufc-308-topuria-vs-holloway-abu-dhabi (last visited Feb 15, 2025)

[13] In a UFC-USADA world, where do State Athletic Commissions come into play? USA Today, https://mmajunkie.usatoday.com/2015/07/in-a-ufc-usada-world-where-do-state-athletic-commissions-come-into-play (last visited Feb 16, 2025)

[14] Id.

[15] Id.

[16] UFC rules: Understanding the Unified Rules of MMA The Body Lock MMA, https://thebodylockmma.com/mma/mma-guide/unified-rules-of-mma/#:~:text=This%20comprehensive%20document%20encompasses%20weight%20classes%2C%20judging%20criteria%2C,creating%20a%20clear%20framework%20for%20MMA%20events%20worldwide. (last visited Feb 16, 2025)

[17] Wanderlei Silva suspended three years for evading May 2014 drug test MMA Fighting, https://www.mmafighting.com/2016/2/17/11036192/wanderlei-silva-suspended-three-years-for-evading-may-2014-drug-test (last visited Feb 16, 2025)

[18] Id.

[19] Id.

[20] No USA fights for “One-eyed pirate” Sharaputdin Magomedov, says Dana White FirstSportz, https://firstsportz.com/no-usa-fights-for-one-eyed-pirate-sharaputdin-magomedov-says-dana-white/ (last visited Feb 16, 2025)

[21] Michael Bisping reveals extent of eye injury as he removes “glass eye” live on podcast TheMacLife, https://themaclife.com/featured-posts/51078/ (last visited Feb 16, 2025)

[22] Id.

[23] What is a doctor stoppage in the UFC? (simply explained) GroundedMMA, https://groundedmma.com/what-is-a-doctor-stoppage-ufc/ (last visited Feb 16, 2025)

[24] Joaquin Buckley carves up Colby Covington, UFC Tampa Main Event stopped due to gruesome cut MMA Fighting, https://www.mmafighting.com/2024/12/15/24321575/joaquin-buckley-carves-up-colby-covington-ufc-tampa-main-event-stopped-due-to-gruesome-cut (last visited Feb 16, 2025)

[25] Id.

[26] Inside Zion Clark’s MMA debut and the battle over who gets to fight ESPN, https://www.espn.com/mma/story/_/id/35260940/zion-clark-mma-fight (last visited Feb 16, 2025)

[27] Id.

[28] Id.

[29] Michael Bisping won the middleweight title while being legally blind on one eye When Michael Bisping Won The UFC Middleweight Title - With One Eye, https://www.sports-king.com/michael-bisping-title-one-eye-3348/ (last visited Feb 16, 2025)