Are the 'Rules of the Game' web articles for using special attacks as attacks of opportunity corroborated by any other source?

Question

To provide some context, I am prepping a new direction for my players in to the the worlds of H.P Lovecraft for a change of pace. So I would like to use the D20 rules for that and I had a mind to try to make that experience more D&D 3.5 compliant, there's not that much work as Call of Cthulhu D20 was designed for D&D 3.0.

I was refreshing my memory as to how modern firearms work in game and noted they behave just like any other ranged attack behaves in D&D 3.x in that they provoke attacks of opportunity. Okay somewhat cinematic but I can appreciate why that should be.

Acknowledging that there are more opportunities in this game world for characters to enter combat and remain unarmed I recalled the articles expanding and adding clarity to attacks of opportunity. Which led me to the old Rules of the Game articles by Skip Williams:

• Attacks of Opportunity (Part One)
• Attacks of Opportunity (Part Two)

To get to the issue at hand from part one:

You provoke an attack of opportunity when you're in a square on the battlefield that a foe threatens and you take some other action that provokes an attack of opportunity.

[...]

Since an attack of opportunity involves a threatened square, a short discussion of exactly when a square is "threatened" is in order:

• A creature threatens all squares into which it can make an armed melee attack.

To be "armed," a creature must wield at least one weapon, either a natural weapon or a manufactured weapon. Most creatures have at least 5 feet of reach, so they threaten all squares adjacent to their spaces (including diagonally). If a creature has a reach of more than 5 feet (by virtue of its size or because it wields a reach weapon, or both) it threatens more squares.

And then from part two:

As noted last month, an attack of opportunity is a melee attack.

You can use any special attack that you can use as a melee attack as an attack of opportunity. That includes disarming, grabbing someone to grapple, sunder, or trip. In the case of a trip attack, you must make the trip attack with whatever weapon you're using to threaten the area where you're making the attack of opportunity.*

Personally this leads to somewhat of an absurdity, if a person attempts to use a handgun within 5 feet of me I am able to use the opportunity to, for example, grapple him IF I happen to be clutching a broken glass bottle (or a regular dagger in standard D&D 3.5) but if I am unarmed I wouldn't get that opportunity.

I have looked at the D&D 3.5 Players Handbook, Dungeon Masters Guide and Rules Compendium for additional sources that explicitly state a special attack can be used as an attack of opportunity but find no reference, though by implication the special attacks mentioned above can be substituted as attacks of opportunity.

So my question is, are these articles considered official RAW or can I be considered to be 'rules compliant' if I simply ignore what Skip Williams wrote about special attacks and attacks of opportunity?

Answer 1

The Player's Handbook includes Table 8–2: Actions in Combat that, in footnote 7, says

These attack forms [i.e. disarm, grapple, and trip] substitute for a melee attack, not an action. As melee attacks, they can be used once in an attack or charge action, one or more times in a full attack action, or even as an attack of opportunity. (141)

Thus, technically, Skip Williams overstates things when he says that you can use any special attack that you can use as a melee attack as an attack of opportunity as that would include other special attacks like aid another and charge that have their own entries (sans footnote 7) on Table 8–2. However, for disarm, trip, and grapple, he's correct.

The Rules Compendium on its table Actions in Combat adds to the list of special attacks that can be used as an attack of opportunity the special attack sunder (9).

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Note: The 3.5 revision—probably accidentally but certainly luckily for monster-fighters everywhere—changed grapple so that it's possible to start a grapple as an attack of opportunity, but the grapple can't be maintained—technically, anyway; see here.