Was There Pass Interference On The Game-Deciding 4th And Goal Play? A Frame-By-Frame Breakdown

  • Dylan Murphy

We touched on it briefly last night, but the Super-Bowl-deciding play came just past the two-minute warning, San Francisco trailing 34-29 and facing a 4th and goal from the five-yard line. Colin Kaepernick, facing immense pressure in his face, threw the ball up for grabs towards San Francisco’s Michael Crabtree and Baltimore’s Jimmy Smith in the right corner of the end zone. Then, controversy.

Jim Harbaugh begged for a defensive holding call, but didn’t get one. So now the all-important question is, did the refs get it right? Before we delve into that answer, it’s important to understand the subtle distinctions between defensive holding, illegal contact and defensive pass interference. A defensive player is allowed to maintain continuous contact to impede an eligible receiver’s progress up to five yards from the line of scrimmage. Any impeding contact beyond that point is deemed “illegal contact” if the ball has yet to be thrown, and the offensive team is awarded five yards and an automatic first down. “Defensive holding,” when occurring between an eligible receiver and a defensive back, is essentially a form of illegal contact, though it has wider applications to all defenders which are not germane to this discussion. Anyway, the portion of the definition that applies here is as follows:

“A defensive player may not tackle or hold an opponent other than a runner. Otherwise, he may use his hands, arms, or body only:

(a) To defend or protect himself against an obstructing opponent.

Exception: An eligible receiver is considered to be an obstructing opponent ONLY to a point five yards beyond the line of scrimmage unless the player who receives the snap clearly demonstrates no further intention to pass the ball. Within this five-yard zone, a defensive player may chuck an eligible player in front of him. A defensive player is allowed to maintain continuous and unbroken contact within the five-yard zone until a point when the receiver is even with the defender. The defensive player cannot use his hands or arms to push from behind, hang onto, or encircle an eligible receiver in a manner that restricts movement as the play develops. Beyond this five-yard limitation, a defender may use his hands or arms ONLY to defend or protect himself against impending contact caused by a receiver. In such reaction, the defender may not contact a receiver who attempts to take a path to evade him.”

And that brings us to this screenshot of the play, in which Jimmy Smith is clearly grabbing Michael Crabtree’s jersey and obstructing his path beyond five yards. Remember, the ball was snapped from the five yard line, and the contact is two yards into the end zone – seven yards from the line of scrimmage:

Ah, but you may have remembered that the ball is in the air. Defensive holding and illegal contact are no longer eligible penalties once the quarterback throws the ball.

The penalties are folded into defensive pass interference, which carries the following definition:

“Actions that constitute defensive pass interference include but are not limited to:

(a) Contact by a defender who is not playing the ball and such contact restricts the receiver’s opportunity to make the catch.

(b) Playing through the back of a receiver in an attempt to make a play on the ball.

(c) Grabbing a receiver’s arm(s) in such a manner that restricts his opportunity to catch a pass.

(d) Extending an arm across the body of a receiver thus restricting his ability to catch a pass, regardless of whether the defender is playing the ball.

(e) Cutting off the path of a receiver by making contact with him without playing the ball.

(f) Hooking a receiver in an attempt to get to the ball in such a manner that it causes the receiver’s body to turn prior to the ball arriving.”

Really, take your pick here. Jimmy Smith commits four out of six possible violations. And so without question, he should have been called for defensive pass interference.


There is an exception to the rule: pass interference fouls are rendered moot if the ball is deemed uncatchable. Though Kaepernick overthrows both Smith and Crabtree, it is hardly out of the realm of possibility that either player could have caught the ball sans interference.

Now, let’s flip the camera around. Here we see Michael Crabtree retaliating by raking his hand across Jimmy Smith’s helmet and shoving him aside. This, by definition, is offensive pass interference.

“Actions that constitute offensive pass interference include but are not limited to:

(a) Blocking downfield by an offensive player prior to the ball being touched.

(b) Initiating contact with a defender by shoving or pushing off thus creating a separation in an attempt to catch a pass.

See here:

The wording of the rule does give Crabtree some leeway: because Smith initiated the contact, Crabtree does have the right to wring himself free, within reason. However, the reason why it does not apply here is because Crabtree initiates new contact – at Jimmy Smith’s head – and therefore is guilty of offensive pass interference.

Now let’s watch it all in slow motion:

So now we’re left with two identical fouls: the first is defensive pass interference, which is an automatic first down and places the ball at the one-yard line because it occurred in the end zone. The second is offensive pass interference, a 10-yard penalty and replay of down. Except in the NFL, neither penalty yardage nor down infraction is tallied consecutively – penalties by both teams generally offset, regardless of yardage, and the down is replayed (there are a few exceptions, none of which apply here).

“If there is a double foul (3-11-2-c) without a change of possession, the penalties are offset and the down is replayed at the previous spot. If it was a scrimmage down, the number of the next down and the necessary line is the same as for the down for which the new one is substituted.”

That Jimmy Smith committed the first penalty, and therefore instigated the second, is irrelevant. But more crucial to the game’s outcome is something that Phil Simms commented on during the broadcast: because both players committed fouls, it was the correct move by the official to keep his flag holstered. This, of course, is more of a traditional sentiment than anything else. It is also a partial extension of the incidental contact rule:

“Incidental contact by a defender’s hands, arms, or body when both players are competing for the ball, or neither player is looking for the ball. If there is any question whether contact is incidental, the ruling shall be no interference.”

But as you see, this contact was hardly incidental. This had more to do with nobody wanting officials to decide late-game plays, so better to keep the flags at bay than fling them around like usual. Of course, the NFL has no rule permitting such behavior – infractions are supposed to be flagged regardless of context. But that’s not what happened here. Both players were disadvantaged from making a play on the ball because of each other’s conduct. But no foul was called. And this is crucial, and where San Francisco 49ers fans, and Jim Harbaugh, could have a gripe: the dual penalties, as explained per NFL rules above, would have offset and 4th down would have been replayed – which means San Francisco would have had another opportunity to take the lead with a touchdown. But remember, this is a literal reading of technical nitpicking. In truth, how often are offensive and defensive pass interference called simulatenously? Never.

Not to mention that there’s this:

“A defensive player is allowed to maintain continuous and unbroken contact within the five-yard zone until a point when the receiver is even with the defender.”

Crabtree had not yet gained even ground (see first screenshot) with Smith, and the contact by both players was barely beyond five yards. Crabtree and Smith’s pass interference therefore fall into the same legal subset, and so no penalty should have been awarded on either side. Furthermore, remember what was stated above: both players were disadvantaged, meaning neither player gained an advantage. At this point it usually becomes a game of splitting hairs, the official deciding which player impeded the other more. And because neither foul was particularly egregious, he choose to let it all go – which, in my opinion, was the only call to make, because a singular flag on either side would have been unfairly punitive.

In situations like this, pass interference rules are just a giant mess. One player could have caught the ball had no interference (which did take place, by definition) taken place. But because there was interference on both sides, and throwing a flag for interference on both players is taboo, it was a no call. Ignoring traditional standards, the down should have been replayed due to offsetting penalties. But the referee’s judgment was in line with what we’ve seen from the NFL, historically.

Again, this is all speculative judgment, and it’s especially difficult for officials in real time under Super Bowl pressure. Anyway, we ask again: judge for yourself.