The media screamed about a “blatant” (aren’t they always?) missed hit on the Titans Kalif Raymond. After Raymond completed his catch, defender C.J. Gardner-Johnson delivered a hard hit on Raymond, forcing a fumble and New Orleans Saints recovery and long return (video).
Yes, it was a hard hit. Yes,, Raymond was unfortunately hurt on the play, and yes, it was at a pivotal moment in the game.
And, the play was legal.
Under the NFL rule interpretations, there cannot be a hit to a defenseless receiver penalty, after the receiver completes the catch process (this extends to players going to the ground under the old catch rule). Under the catch interpretation, Raymond had completed the process of the catch and by definition has the ability to ward off or brace for contact. Video shows him lowering his head preparing for contact and/or fight for more yardage.
You could also make an argument that Gardner-Johnson was trying to adjust his target to the side so as not to deliver a blow to the head.
Also, instant replay reviewed the play to see if it was a fumble or incomplete pass. The call remained a catch and fumble. Replay wasn’t able to order the officiating crew to drop a flag if officials in New York deemed Gardner-Johnson’s hit was illegal. However, by ruling a catch, it essentially confirms there cannot be a defenseless receiver hit.
Not every hit to the head is a foul, even if the hit results in injury.