I believe so too. It's making me think maybe I should sub a carded player straight away.
I played Normal tackling all last season and never got a red, maybe I was just lucky.
My team had full morale/fitness and he wasn't present but he wasn't abandoned either.
The first one, AMC I don't understand why he got a red when I was playing normal tackling, own half and there was no DMC to tackle so I'm not sure how many tackles he could put in in that match. The second one I understand as the opponent had a 7 star AMC vs my 5 star DMC so maybe he had to stick the boot in a lot.