In the wake of a San Francisco federal court ruling that coach Chuck Noll of the Pittsburgh Steelers did not slander George Atkinson of the Oakland Raiders for saying among other things, that the defensive back demonstrated an "intent to maim," comes another pertinent decision.

U.S. District Court Judge Richard Matsch dismissed a &1 million suit by defensive back Dale Hackbart (a onetime Redskin) of the Denver Broncos, who charged that he suffered a neck injury as a result of "outrageous conduct" by running back Boobie Clark of the Cincinnati Bengals.

Harkbart said Clark hit him with a forearm blow to the back of the head while trying to get free during a pass play in the end zone. Judge matsch observed, "Civil courts cannot be expected to control the violence in professional football."

Mike Brown, assistant general manager of the Bengals, said of the decision in favor of his funning back. "When federal courts get involved, they're getting into something they're not physically equipped to handle.It's difficult enough for a referee or a football coach to determine if a rule has been infracted . . ."

Now, more than ever there will be a new emphasis required by the National Football League to decide the difference between "agressiveness" and "violence."

Will there be more penalties called this season with the risk of spoiling the entertainment for the fans? Or will the exposure of the problem in those two court cases prompt the league to get its message across to "cool it" without an excessive number of flagcalls.

In the AFC last season, Miami drew the fewest penalties, 70 to 71 for the New York Jets; Pittsburgh the most, 110, to 109 for Tampa Bay, Cleveland and Oakland had 107.

In the NFC, Minnesota had the fewest, 77 to 83 for New Orleans. The Redskins had 90.