The Tampa Bay Times reported that no replays were shown inside the stadium, so some Bucs players thought the issue might have been over how much time should have been left on the clock.

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Fox ran replays of the play as the review unfolded, as Summerall and Madden agreed that Emanuel had caught the ball. “I don’t think you can take that one away,” Madden said. “I don’t think you can either,” Summerall concurred.

But that’s exactly what happened. As referee Bill Carollo announced to the crowd and the viewing audience that the catch was going to be overturned, Emanuel came up from behind him to complain and was even overheard shouting, “Oh, my God!” In an NFL Films segment that aired last year, Emanuel said with a laugh, “I hope that’s all I said.”

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The Bucs ran two more plays. Both fell incomplete, ending the game. The Rams went on to beat the Tennessee Titans in the Super Bowl.

“The shock and awe of you doing something so routine, and all of a sudden now it’s considered not good enough—I think that’s something I’ve had to live with for a long time,” Emanuel told NFL Films.

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After the game, Dungy assumed the call was correct—“That’s why we have replay,” he told reporters—only to find himself stunned when he finally saw the replay the next day.

“I was flabbergasted,” Dungy told the Tampa Bay Times. “I immediately called the league office and said, ‘This has been a catch for 100 years and it always will be a catch. And if it isn’t a catch, we got to take 100 catches that Cris Carter had when I coached in Minnesota.’ No one had ever discussed that a play like that might not be a catch.”

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Oddly enough, the league adjusted the rule that offseason specifically to address what happened to Emanuel—a change known colloquially as the Bert Emanuel Rule. Yet that was hardly the end of the discussion of catches that might not be catches.


Then, as now, the NFL rule book got in the way of logic and common sense.

“Back then, the rule was if any part of that football touched the ground, which the nose of the ball does [on that play], it was incomplete,” former NFL senior VP of officiating Dean Blandino told NFL Films last year.

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And so the NFL came up with the Bert Emanuel Rule.

“Everyone in America knew it was a catch,” Dungy said. “But we had to write a rule that said it was a catch. Pretty ludicrous when you think about it.”

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If only that were the end of it. Per Bleacher Report, the wording of the Bert Emanuel Rule stated that a pass catcher “must have possession, control and make a football move”—and isn’t automatically incomplete just because the ball touches the ground. “As long as he maintained control of the ball, it’s a catch,” Dennis Green, co-chair of the competition committee, explained at the time.

In 2004, former referee Jerry Markbreit explained the definition of “a football move” in a column for the Chicago Tribune:

“When a catch is made by a receiver who comes down with both feet on the ground, the ‘football move’ would be: stretching for a first down, diving out-of-bounds or running with the ball. If the ‘football move’ is accomplished, and the receiver is then hit and the ball comes out, it is ruled a catch and fumble, instead of an incomplete forward pass.”

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It’s laughable to read that definition now, in light of all the overturned catches that have happened since. Had Markbreit’s explanation still been the rule, James’s touchdown would have counted and the Steelers would be in position to secure home-field advantage in the weeks ahead. But the league instead insisted on mangling the rule by further legislating it into absurdity.


By 2007, according to Bleacher Report, the rule book no longer had any reference to “football move.” Instead, as referee Ed Hochuli told the Atlanta Falcons’ website, it would be considered a catch whenever a receiver simply had two feet down and possession of the ball.

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“Sometimes there’s a situation where there were three steps and the ball would come out and it would be correctly ruled an incomplete pass,” Hochuli said. “So, the receiver gets a second foot down, gets hit and the ball comes lose—we would have a fumble rather than an incomplete pass.”

Seems simple enough. But look at the way a catch was defined in the 2007 rule book:

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That last clause, the one that says “control is maintained after the ball has touched the ground” wound up being expanded by 2009, according to the New York Times:

“Rule 8, Section 1, Article 3, Item 1 of the NFL Rule Book (page 51) states that ‘if a player goes to the ground in the act of catching a pass (with or without contact with an opponent), he must maintain control of the ball after he touches the ground, whether in the field of play or in the end zone. If he loses control of the ball, and the ball touches the ground before he regains control, the pass is incomplete. If he regains control prior to the ball touching the ground, the pass is complete.”

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In 2009, Oakland Raiders receiver Louis Murphy had a TD taken away because of this rule. The following year, Detroit Lions wideout Calvin Johnson famously got caught in the crosshairs of it, too:

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So what it did the league do? More changes, of course! This is how the 2011 rule book defined a catch at 3-2-7, with the changes in red:

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And again later at Rule 8-1-3, also with the changes in red:

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As Dungy put it:

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After some minor wording changes in 2012, the “Fail Mary” play involving the replacement officials led the league in 2013 to clarify what must happen in a case of simultaneous possession. Then came the Dez Bryant catch in the 2014 playoffs, which took a go-ahead touchdown away from the Dallas Cowboys in a game they wound up losing to the Green Bay Packers. That led to these changes (in red) to Rule 3-2-7 the following offseason, with additional tweaks at 8-1-3:

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Look how long that shit is! But the league kept making additions, and yet there continued to be unclear plays, with SB Nation finding there were at least five such instances in November 2015 alone. Which meant there had to be even more changes. Here, in red, is what was done to 3-2-7 at Item 2 in 2016:

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Along with these adjustments (in red) to the wording of Rule 8-1-3(c):

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Mercifully, the competition committee had nothing to add to the catch rule for this year. But that could change this offseason. Steelers head coach Mike Tomlin is on the competition committee, and he ain’t happy:

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Emanuel, whose Twitter name is TheBertEmanuelRule, watched the end of Patriots-Steelers the other night and thought Jesse James scored a touchdown.

“He’s established possession, he has control, he’s reaching now, ball across the goal line—touchdown,” Emanuel told me. “Same thing I saw with Dez Bryant. Dez Bryant juggles it, he catches it, he maintains control. A receiver would never, ever reach unless he has control. He will always focus on maintaining control of the ball. Once he reaches, in his mind, control is established.”

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Instead, according on the rule and the way it’s commonly interpreted, a player like James can grasp a pass out of the air with his back to the end zone, turn and advance the ball nearly two yards, and even cross the plane—all without actually making a catch.* The best solution, Emanuel said, would be for the league to go back to something on the order of the original Bert Emanuel Rule, to something that says when a receiver has both feet or one knee or one butt cheek or whatever on the ground while controlling the ball, he becomes a runner. In which case, James would have scored a touchdown the instant the ball crossed the plane of the goal line.

“It just doesn’t make sense to me, it logically doesn’t make sense to me,” Emanuel said. “So you need to be classified as a runner—if you have the ball, you’re a runner. Whether you’re diving for extra yardage, whether you’re running for extra yardage, whether you’re falling for extra yardage, you are classified as a runner.

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“My thought is the process stops when the ball is in my hand, and for a split second as I’m moving forward, it does not move at all. It does not move. I know in my head when it’s a fumble, or when it’s a catch.”

* An earlier version of this post incorrectly stated that the officials would have ruled James had fumbled if the ball been knocked from his hands before it hit the ground.