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Randa Markos thought she deserved the win over Alexa Grasso at UFC Fight Night 114. Two of the three judges disagreed. But as she fumed both in person and on social media after the fight, Markos was already throwing around the idea of an appeal.

“I felt that I did enough to win,” Markos (7-5 MMA, 3-4 UFC) told MMAjunkie after the fight. “You need to win at least two rounds to get a victory. I thought I won two rounds, and the last was close. So I think I won that fight. … I feel I’m definitely going to try to fight that. Hopefully I get the victory.”

Obviously, there’s a big difference between talking about an appeal and actually filing one, but if Markos does challenge the result she wouldn’t be the first. Fighters all over the world have appealed to have results overturned for a variety of reasons, even if successful appeals are few and far between.

That’s not to say it can’t happen, however. Former Invicta FC bantamweight champion Tonya Evinger retained her title thanks to an appeal that overturned her submission loss to Yana Kunitskaya last year. But Evinger was successful because, while citing a referee’s misapplication of the rules, she managed to meet the very narrow requirements for a winning appeal, which isn’t so easy to do in most cases.

Most athletic commissions adhere to an appeals process that’s similar to the one laid out by the Nevada Athletic Commission, which provides only three circumstances under which an appeal might succeed. Under NAC 467.770, the commission insists that it will not overturn a result unless:

1. The Commission determines that there was collusion affecting the result of the contest or exhibition;
2. The compilation of the scorecards of the judges discloses an error which shows that the decision was given to the wrong unarmed combatant; or
3. As the result of an error in interpreting a provision of this chapter, the referee has rendered an incorrect decision.

Markos’ bout was contested in Mexico City, putting it under the jurisdiction of the Mexican Federacion de Artes Marciales Mixtas Equidad y Juego Limpio. The FAMMEJL doesn’t spell out an exact appeals procedure on its website, but a UFC official confirmed that it would follow the same guidelines in use in Nevada.

That’s bad news for Markos, should she decide to appeal the loss. Challenging a judges’ decision would require proving either collusion or a mathematical error in adding up the scorecards. The former would likely be very difficult and require an exhaustive investigation, while the latter would be as simple as combing through the scorecards with a calculator in hand.

But as we’ve seen in the past, even fighters with legitimate complaints don’t always face great odds. The Texas Department of Licensing and Regulation recently shot down Dustin Poirier’s appeal of a no-contest stemming from illegal knees thrown by Eddie Alvarez at UFC 211.

In 2015, the Nevada commission declined to overturn Francisco Rivera’s appeal of a submission loss to Urijah Faber that came shortly after an eyepoke at UFC 181, opting instead to stick to the rigid definition of its own statute requiring an “error in interpreting” the rules on the part of the referee. If a referee simply misses a foul – even a foul clearly evident on replay – it isn’t enough to overturn the result on appeal, according to the NAC.

So where does all this leave Markos, or any other fighter hoping to appeal a decision he or she doesn’t like? Probably with more complaints than hope. Judges may make questionable calls at times, but commissions aren’t in the habit of revisiting them.

For complete coverage of UFC Fight Night 114, check out the UFC Events section of the site.

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