Billy Dodds believes Steven Gerrard will be "untouchable" when he goes before the SFA next month.
The Rangers boss has been charged after suggesting Alfredo Morelos would have been red carded over a challenge for which Dundee United 's Ryan Edwards escaped punishment.
Gerrard reacted to the incident following his side's 4-0 win at Ibrox on September 12.
He's been charged under SFA disciplinary rule 72, which prohibits criticism of match officials that implies bias or incompetence.
But former Rangers striker Dodds insists Gerrard was being "cute" and simply posed a question.
He reckons the club's scathing statement earlier on Wednesday shows they are confident no action will be taken against the manager.
Dodds told BBC Sportsound: "He's being cute. If I was a manager and that happened and I posed a question to somebody... I think Steven Gerrard knew when he asked he was probably untouchable.
"That's why Rangers came out with the statement about being 'bemused' and 'perplexed'."
He continued: "I don't agree with Steven Gerrard to compare players and tackles, I think with this one, though, he's been cute about it. He's asked a question.
"He's not made a statement, he's asked a question: 'I wonder what the answer would be'.
"He's not inferred, he's not made a statement, he's not thrown it to a referee, not called him out.
"He has asked him a question, he has asked the authorities a question. I just don't see how they can touch him, I really don't."
Dodds admits Gerrard's prospects at the October 8 hearing would be much different if he'd directly attacked Edwards or ref Kevin Clancy over the incident.
Morelos was left with a gash on his leg and had to be carried off but his manager refused to call for retrospective action.
Dodds insists he'll be astonished if Gerrard is punished.
He said: "If Steven Gerrard had said: 'The boy's out of order, I can't believe they're not doing anything', making statement after statement, slamming the player, slamming the club.
"But he's not, he's thrown it out as a question, he's been cute.
"For me, he can't be touched. If he's touched... well, listen, the authorities have surprised us before with these sort of things.
"But I'll be amazed if they touch him."