Everton manager David Moyes may face Football Association punishment after he was sent to the stands during the win at West Bromwich Albion.
Moyes was already fuming over an 18th-minute penalty awarded against Alan Stubbs when a late challenge on Wayne Rooney led to him confronting referee Steve Bennett on the touchline.
Bennett said after Everton's 2-1 win: "David Moyes was removed from the technical area after 38 minutes for foul and abusive language and improper behaviour."
Moyes did not take the post-match press conference but his
assistant Alan Irvine admitted he had lost his cool.
Irvine said: "David felt the referee had made a few mistakes and the tackle came on top of one or two other incidents.
"He complained about the fact that it was the same referee who gave a controversial penalty against us at Southampton earlier in the season."
David Moyes was removed from the technical area after 38 minutes for foul and abusive language and improper behaviour
Irvine praised his side's fighting spirit for overcoming an Albion side who had the better of possession and first half chances.
Irvine added: "We've come from behind quite a few times this season and we needed a lot of character to do that here.
"We didn't play well but we hung in there and it's the mark of a team with a lot of spirit and a lot of character that you can do that."
Irvine added: "Six points out of six gives us a massive boost going into the tough games we have ahead."
Albion's scant reward for another performance bristling with effort was that they managed to cling onto their Premiership status for another week.
Boss Gary Megson admitted it was the same old story as his side's profligacy in front of goal once again cost them dear.
Megson said: "We did the same thing as we've done in 80 or 90% of our games this season.
"We gave it everything and worked our socks off and were certainly the best team in the first half.
"We had some excellent chances but didn't convert any in outfield play and unusually we're talking about two goalkeeping clangers which cost us."