Liebsack, a side judge covering the goal line, had thrown a penalty flag when Browns running back Terry Kirby fell out of bounds, rolling up on Liebsack's left leg. The accident occurred late in the second quarter.
Liebsack laid on the ground for a few minutes and was eventually carted off the field.
Kirby caught a pass from Browns quarterback Ty Detmer in the middle of the field, cut outside and was trying to break into the end zone when he hit Liebsack. The Browns were called for holding on the play.
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