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What Is the Rarest Penalty Called in the NFL?

The Palpably Incomplete Pass: A Rule Few Know Exists

Let’s be clear about this: the palpably incomplete pass isn’t just rare—it’s a ghost. It appears once every decade or so, vanishes just as quickly, and leaves fans scratching their heads. The rule, officially buried in Section 8, Article 3 of the NFL rulebook, states that if a passer, under no pressure, deliberately throws a ball short of the line of scrimmage with no realistic chance of completion, it’s not a legal forward pass. It’s treated like a fumble. That means the offense can’t advance the ball, and the defense can recover and score. But here’s where it gets tricky: “no realistic chance” is entirely subjective. Was the QB injured? Was he trying to avoid a sack? Or did he just give up?

And that’s the heart of the problem. Referees are trained to avoid making obscure calls unless the situation is undeniably obvious. The 1990 Bears-Packers game saw the first recorded instance—Mike Tomczak “passed” the ball a yard forward while lying on the ground after a scramble. No attempt. No momentum. Just a limp toss. Flag down. Palpably incomplete. The second? 2021. Jared Goff, Lions vs. Seahawks, fourth quarter, down by four. He drops back, takes a step, then flops forward, releasing the ball as he hits the turf. No defenders near him. Ball lands two feet in front. Whistle. Same call. Two calls in 64 years. That’s rarer than a perfect game in baseball.

Origins of the Rule: Why It Was Created

The palpably incomplete pass was born in an era when clock management was more chaotic. In the 1940s and 50s, teams would exploit the forward pass rule by having quarterbacks fall down and toss the ball forward to stop the clock without using a down. The league realized this was gaming the system. So they introduced the concept: if there’s no genuine attempt to complete, it’s not a pass. It’s a surrender. But because it’s so situational—only applicable when the QB isn’t under duress and makes no effort—it’s almost never triggered. Most sacks, even flops, involve some level of contact or evasion. That’s enough to shield the play from this penalty.

How It Differs from Intentional Grounding

This is where people don’t think about this enough. Intentional grounding is common—about 10–15 times per season. It happens when a QB, under pressure, throws the ball away to avoid a sack. But there are conditions: the ball must travel past the line of scrimmage or land near an eligible receiver. If not, it’s a penalty. The palpably incomplete pass, on the other hand, doesn’t require pressure. It’s about the lack of intent. So if a QB is wide open, drops back, and just chucks it short like he’s tossing trash into a bin? That’s palpably incomplete. But because it’s so subjective, referees hesitate. They’d rather call nothing than explain a rule most fans have never heard of.

Other Contenders for Rare Penalty Status

While the palpably incomplete pass takes the crown, it’s not alone in the obscurity hall of fame. There are other penalties so rare they might as well be urban legends. The 12-men-on-the-field penalty? Common. False start? Daily. But then you get to things like the “palpably unfair act” or “leaping over the line of scrimmage on a field goal attempt.” Those happen once every few seasons—if that.

Palpably Unfair Act: The Nuclear Option

The palpably unfair act clause (Rule 12, Section 3, Article 1) allows referees to assess any penalty they deem necessary if a play is egregiously unsportsmanlike. It’s been used maybe a dozen times in NFL history. One famous example: 2013, Ravens vs. Patriots. Billy Cundiff, kicking a field goal, had a teammate leap over the line to block. Illegal. But the refs didn’t see it. After review, they invoked the palpably unfair act—gave Baltimore another chance. The kicker missed again. Another time: 1989, 49ers. Joe Montana fumbled, but a teammate punched the ball forward and recovered. The refs called it unfair—no advancement allowed. It’s a catch-all, used when no existing rule fits. But because it’s so broad, it’s also feared. Coaches hate it. Players don’t know when it might drop.

Leaping Penalty: A Forgotten Quirk

This one sounds made up. But it’s real. Since 2005, offensive linemen can’t leap over the line of scrimmage to block a field goal or extra point. It’s a 15-yard penalty. The rule exists because, in the 1990s, teams started training linemen to jump like shot-putters to swat kicks. Some were clearing 6–7 feet. Dangerous? Maybe. Spectacular? Absolutely. But after a few scary collisions, the NFL banned it. Only a handful of calls since—most recently 2015, when the Bears tried it against the Packers. Flag thrown. Kick stood. It’s rare not because it’s obscure, but because teams know better. They’d rather practice timing than risk 15 yards.

Why So Few Calls? The Human Factor Behind the Whistle

Here’s the truth no one talks about: referees don’t want to make rare calls. It draws attention. It invites second-guessing. A palpably incomplete pass? That’s not just a flag—it’s a press conference. And that’s exactly where the hesitation comes in. In a league where consistency is already under fire, no crew wants to be the one that “invented” a penalty. Except that it’s not invented. It’s written. It’s just buried.

And because the standard is “no genuine attempt,” it’s nearly impossible to prove. Was Goff trying and just weak-armed? Was Tomczak injured? The refs have to decide in real time. No replay review for judgment calls like this. So they default to no call. Which explains why you can go a decade without seeing it. As a result: the rule exists, but it’s functionally dormant. It’s like a fire alarm with a faded label—technically operational, but no one remembers how to use it.

Palpably Incomplete Pass vs. Intentional Grounding: A Side-by-Side Look

Let’s break it down. Intentional grounding requires three elements: the QB is under pressure, the ball doesn’t reach the line of scrimmage or a receiver, and there’s no realistic target. Penalty: loss of down and 10 yards (or spot of foul, whichever is worse). But the down is still used. Palpably incomplete? No pressure needed. If the ref decides the passer made no effort, it’s treated like a fumble. The ball is dead where it lands. Defense can recover and score. But the offense keeps the down. That’s a massive difference. Imagine: fourth and 10, QB flops and tosses it short. No penalty? Or palpably incomplete? The game keeps going. That could change outcomes.

The issue remains: one is about survival (grounding), the other about surrender (palpably incomplete). One is reactive. The other is passive. And yet—same outcome in practice: incomplete pass, ball back to offense. So why call it? Because in theory, the defense should have a chance to recover. But in reality? The whistle blows instantly. No recovery. No controversy. Just confusion.

Frequently Asked Questions

Has the palpably incomplete pass ever decided a game?

No. Not directly. The two official calls didn’t alter outcomes. Goff’s call in 2021? Fourth quarter, but the Lions still lost. Tomczak’s in 1990? Bears lost anyway. But imagine: fourth quarter, down by three, one minute left. QB flops, tosses it. Defense recovers, runs it back. That could end a game. But it’s never happened. Data is still lacking, simply because the situation is too rare. Experts disagree on whether it should be enforced more strictly—or scrapped altogether.

Can the defense score on a palpably incomplete pass?

Yes, in theory. Since it’s treated like a fumble, the ball is live. If the defense recovers and advances, they can score. But in practice, the whistle usually blows the moment the ball lands. Referees don’t want a free-for-all over a two-foot toss. So while the rule allows it, the enforcement prevents it. That said, if the defense scooped and ran before the whistle? They’d have a case. But no one’s tested it yet.

Why don’t teams try to exploit this rule?

Because they can’t. To trigger it, the QB has to show no attempt. That means no wind-up, no follow-through, no motion toward a target. If he fakes a throw or steps into it, it’s a legal pass. And if he’s under pressure? Grounding, not palpably incomplete. So the window is tiny. Plus, giving up on a play like that? Coaches would bench you. It’s a career-limiting move. Suffice to say, no quarterback wants to be known as the guy who “palpably” quit.

The Bottom Line: Obscure, But Not Obsolete

I am convinced that the palpably incomplete pass should stay—but with clearer guidelines. Right now, it’s a rule in exile. Feared by referees, ignored by players, unknown to fans. But it exists for a reason: to prevent manipulation. The NFL has spent decades closing loopholes. This isn’t one to ignore. That said, the current enforcement is broken. Referees need training. Fans need education. And the league should clarify what “no genuine attempt” actually means. Is a one-handed shove forward enough? What if the QB is hurt? These questions linger. Honestly, it is unclear whether we’ll see another call in the next decade. But when we do, it’ll spark chaos. And maybe, just maybe, that’s what makes it beautiful. It’s a reminder that football isn’t just stats and speed. It’s nuance. It’s judgment. It’s a 40-yard pass, a 2-inch toss, and the difference between a sack and a whistle. And that? That changes everything.

💡 Key Takeaways

  • Is 6 a good height? - The average height of a human male is 5'10". So 6 foot is only slightly more than average by 2 inches. So 6 foot is above average, not tall.
  • Is 172 cm good for a man? - Yes it is. Average height of male in India is 166.3 cm (i.e. 5 ft 5.5 inches) while for female it is 152.6 cm (i.e. 5 ft) approximately.
  • How much height should a boy have to look attractive? - Well, fellas, worry no more, because a new study has revealed 5ft 8in is the ideal height for a man.
  • Is 165 cm normal for a 15 year old? - The predicted height for a female, based on your parents heights, is 155 to 165cm. Most 15 year old girls are nearly done growing. I was too.
  • Is 160 cm too tall for a 12 year old? - How Tall Should a 12 Year Old Be? We can only speak to national average heights here in North America, whereby, a 12 year old girl would be between 13

❓ Frequently Asked Questions

1. Is 6 a good height?

The average height of a human male is 5'10". So 6 foot is only slightly more than average by 2 inches. So 6 foot is above average, not tall.

2. Is 172 cm good for a man?

Yes it is. Average height of male in India is 166.3 cm (i.e. 5 ft 5.5 inches) while for female it is 152.6 cm (i.e. 5 ft) approximately. So, as far as your question is concerned, aforesaid height is above average in both cases.

3. How much height should a boy have to look attractive?

Well, fellas, worry no more, because a new study has revealed 5ft 8in is the ideal height for a man. Dating app Badoo has revealed the most right-swiped heights based on their users aged 18 to 30.

4. Is 165 cm normal for a 15 year old?

The predicted height for a female, based on your parents heights, is 155 to 165cm. Most 15 year old girls are nearly done growing. I was too. It's a very normal height for a girl.

5. Is 160 cm too tall for a 12 year old?

How Tall Should a 12 Year Old Be? We can only speak to national average heights here in North America, whereby, a 12 year old girl would be between 137 cm to 162 cm tall (4-1/2 to 5-1/3 feet). A 12 year old boy should be between 137 cm to 160 cm tall (4-1/2 to 5-1/4 feet).

6. How tall is a average 15 year old?

Average Height to Weight for Teenage Boys - 13 to 20 Years
Male Teens: 13 - 20 Years)
14 Years112.0 lb. (50.8 kg)64.5" (163.8 cm)
15 Years123.5 lb. (56.02 kg)67.0" (170.1 cm)
16 Years134.0 lb. (60.78 kg)68.3" (173.4 cm)
17 Years142.0 lb. (64.41 kg)69.0" (175.2 cm)

7. How to get taller at 18?

Staying physically active is even more essential from childhood to grow and improve overall health. But taking it up even in adulthood can help you add a few inches to your height. Strength-building exercises, yoga, jumping rope, and biking all can help to increase your flexibility and grow a few inches taller.

8. Is 5.7 a good height for a 15 year old boy?

Generally speaking, the average height for 15 year olds girls is 62.9 inches (or 159.7 cm). On the other hand, teen boys at the age of 15 have a much higher average height, which is 67.0 inches (or 170.1 cm).

9. Can you grow between 16 and 18?

Most girls stop growing taller by age 14 or 15. However, after their early teenage growth spurt, boys continue gaining height at a gradual pace until around 18. Note that some kids will stop growing earlier and others may keep growing a year or two more.

10. Can you grow 1 cm after 17?

Even with a healthy diet, most people's height won't increase after age 18 to 20. The graph below shows the rate of growth from birth to age 20. As you can see, the growth lines fall to zero between ages 18 and 20 ( 7 , 8 ). The reason why your height stops increasing is your bones, specifically your growth plates.