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As has already been stated...there is no rule basis for calling a batter out for throwing the bat.
I also covered this issue in the NFHS class I facilitated earlier this week. I can't tell you the number of times I have seen umpires (mostly rec-level with little or no training) call a batter out for throwing a bat. They seem to think they need to "punish" the batter somehow....
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It's what you learn after you think you know it all that's important!
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