Carlton coach Michael Voss criticised Durham's collision with Adam Cerra on Sunday night at the MCG as a "black-and-white" incident.
Durham will serve a two-game ban for forceful front-on contact, with the bump graded as careless conduct, high impact and high contact.
Essendon will start at long odds against the Cats next Saturday night at the MCG and then have only a five-day break before heading west to play Fremantle, who have won their last three games.
Cerra was left with a black eye after his collision with Durham early in the second term of the eight-point Carlton win.
The Carlton midfielder was bent over contesting a ground ball when Durham, also low to the ground, collected Cerra with a heavy bump.
While a doctor went onto the ground to check Cerra, it was another 14 minutes before the player was taken off for a concussion assessment.
He was cleared and played out the game.
Michael Voss and Brad Scott have addressed Sam Durham's bump on Adam Cerra.#AFLBluesDons pic.twitter.com/XplbVmNlDL— AFL (@AFL) June 8, 2025
"We probably took quite a cautious approach and did the HIA (head injury assessment), so we followed that through," Carlton coach Michael Voss said.
"I would have thought the incident is more the conversation for me."It's pretty black-and-white - you just can't do that any more.
"He (Cerra) seems fine ... but this is one part of ongoing checks for the player."
Durham was among Essendon's best as they recovered from a poor start to pile the pressure on Carlton and he is a big loss for the Cats and Dockers games.
"It will be what it will be ... there's nothing I can do about it," Essendon coach Brad Scott said post-game.
"Imagine being a player now ... I understand all the challenges in the game around health and safety, but players probably have a more difficult job now in terms of duty of care to their opponents than they've ever had.
"Durham is a 'go ahead'-type player and as hard at the ball as anyone, and that's really what we encourage him and our players to do."
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