Did Ravens’ intentional safety fall into gaps in the rulebook?

Week 12: Bengals at Ravens (video)

With 11 seconds remaining in  the game, the Ravens are in punt formation. Punter Sam Koch took the ball 23 yards to the end zone to take an intentional safety, but multiple holding fouls were committed by the Ravens to allow them to burn all the time off the clock. Whether this was done fairly is a topic of conversation, but let’s step through the play as called.

Since the holding fouls occurred in the field of play, the safety is only available to the Bengals by Koch stepping out of bounds. Therefore, the holding penalties have to be declined to allow the score.  Without the penalty, there is no extension of the quarter allowed. The holding fouls can only be applied to fourth down, which cannot be repeated, since it is an offensive foul with none of the quarter-extending exceptions applicable. (Fifteen-yard fouls are the only ones allowed to carry forward to the kickoff after a score.)

However, if there is a holding foul in the end zone, the penalty can be used to create the safety, rather than the dead ball in the end zone. In that case, there is a specific provision to have a safety kick on an untimed down. This is because the safety kick is created by the penalty, and not that there was a safety on a play that happened to have a penalty.

The Ravens also pulled off a similar play in Super Bowl XLVII to run out the clock (video). Referee Jerome Boger and umpire Darrell Jenkins did not throw a flag for holding, but it also would not have any effect on the play.

The question is whether this is a palpably unfair act, an overarching rule that gives the referee discretion to make “any equitable ruling” for extraordinary circumstances. There is no record of this unilateral authority ever being invoked in an NFL game.

Palpably unfair acts entered the conversation three weeks ago when the 49ers committed multiple deliberate defensive holds to keep the Saints from gaining yardage and taking time off the clock. There are no penalty enforcements to add time back onto the clock, except that a palpably unfair act could be used in that fashion. Football Zebras  has confirmed that senior vice president of officiating Dean Blandino has discussed this possibility with the crews that a palpably unfair act could be invoked to restore time to the clock for deliberate holding foul, but only after a team’s coach has been warned.

In this case, there are multiple offensive holding fouls, but the parallel is the same: a tactic to deliberately drain the clock. A palpably unfair act could not be invoked, because the Ravens bench would receive a warning first, which of course is obviated by the expiration of the game clock.

By making the warning a part of the process, Blandino’s actions  give us a strong indication that this will be sorted out in the offseason. Midseason rule or procedural changes may be made for the remainder of the season, but these automatically go on the Competition Commitee’s agenda for permanency. The warning also serves as a means to avoid invoking this rule for the first time in league history, as a coach will likely heed the warning.