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Buffalo Bills Rulings Review: Week 3 (2022)



Well, we knew this would be a tough one. After two thoroughly dominant performances, the Buffalo Bills travelled into the South Florida heat to take on the Miami Dolphins. The weather was unbearably warm, the team was uncommonly thin with injuries, and the Dolphins happen to be a pretty good football team.

The Bills suffered their first loss of the season, dropping a weird game 21-19. Buffalo played well enough to win but failed to make the crucial plays when they needed them most. It’s difficult to place significant blame on the officials when the Bills blew seemingly every clutch opportunity they had, but nevertheless, there are a few calls to discuss from Sunday’s game.

The Buffalo Bills committed more penalties for more yardage than the Miami Dolphins did, which can happen when a team must play their backups. Buffalo still had only seven penalties for 52 yards, each number lower than last year’s average. Of them, three were on offense for 30 yards, and four were on defense for 22.

Miami played, at least in the eyes of the officials, a comparably cleaner game. They only had four penalties for 20 yards — two on offense and two on defense, each for a measly ten yards.

Alex Kemp was the referee for Sunday’s game. Kemp was not assigned a Buffalo Bills game in the 2021 season, but did call two Bills home games in 2020, both of which were wins. This is his fifth year as a referee and he was assigned playoff games in his third and fourth seasons, his first years of playoff eligibility. Plainly, the NFL thinks he’s a solid official.

Honestly, I thought they had a fine game. The Bills have ten other reasons why they lost the game beyond Kemp and his crew. The Bills were sloppy and they know it, but that’s not to say that there were a few interesting rulings that happened on Sunday. Here are the five I’d like to talk about the most.

1. Unnecessary Roughness, Miami. Q1, 11:41.

On Buffalo’s opening drive, they faced a 2nd and 2 from Miami’s four-yard line. Having faced significant pressure all drive, OC Ken Dorsey called a wide receiver screen. QB Josh Allen got the ball out quickly to WR Stefon Diggs, but the play got blown up behind the line of scrimmage.

Correctly, the officials blew the play dead for forward progress. However, the players kept fighting after the whistle, and CB Xavien Howard body-slammed Diggs. Predictably, the wide receiver got right in Howard’s face and a scrum ensued. The officials correctly penalized Howard for unnecessary roughness. Due to the placement of the ball, the penalty was half the distance to the goal, but gave the Bills a first down.

It’s never fun as an official to have to get an unsportsmanlike play that early in a game. It often indicates that the rest of the game might get chippy, and it forces an official to be keenly aware of similar place and ensure not to miss one.

2. No Call for Unnecessary Roughness. Q1, 00:12.

This was a weird play that you really only noticed on replay. On a 2nd and 9, DE Melvin Ingram rushed against LT Dion Dawkins and tried to push the left tackle into the quarterback. Just as Allen was releasing the ball, Dawkins’s back contacted Allen’s back, which impacted the throw. But at the same time, Ingram stuck his left leg in the air and appeared to kick Allen in the chest, which also impacted the throw.

No flag…

Originally tweeted by Luke Murphy (@angercrown) on September 25, 2022.

It’s impossible to gauge Ingram’s intent here. Did he trying to injure? Was he a little off-balance and tried to right himself? Was he simply trying to impact the throw by any means necessary? Intent doesn’t matter with respect to unnecessary roughness, only unsportsmanlike conduct. With unsportsmanlike conduct, officials have to judge the intent of the player; were their actions unsportsmanlike or not? With unnecessary roughness, all an official has to judge is whether the play was unnecessary and needlessly physical in nature.

By definition, this play fits the bill for unnecessary roughness. Given the penalty on Howard on the first drive, perhaps this was in the back of the umpire’s mind. Perhaps he simply didn’t see the leg kick — there’s a good chance he was blocked out from where he was standing.

3. Roughing the Passer, Buffalo. Q2, 2:28.

On the play immediately preceding the two-minute warning, the Dolphins had a 3rd and 3 from their own 21. Quarterback Tua Tagovailoa completed an eight-yard pass, but was pushed by LB Matt Milano long after releasing the ball. In a similar play to the one that injured QB Lamar Jackson in Buffalo’s 2020 Divisional Round game, Tagovailoa hit his head hard on the ground.

Correctly, the officials flagged Milano for roughing the passer. While it was not a violent hit, it was long after the quarterback released the ball. I doubt any Bills fan disagrees with the call, but I bring it up based on the outcome of the play. The quarterback could not walk following the hit.

It’s something an official hates to see happen to any player, much less a prominent quarterback. The decision to allow Tagovailoa back in the game was not referee Alex Kemp’s to make, but put yourself in his position for a second: you’ve just correctly called a foul on a play that injured a player, to the point where the player cannot walk. You go into your locker room to talk the half over with your crew and then see the player — who 25 minutes earlier could not stand up — back on the field.

Do you throw a flag any time a defensive player goes near him? If the quarterback gets sacked, do you rush in immediately and attempt to protect him? It has to be the most uncomfortable feeling for a referee to have and, in a league that stresses player safety, Kemp must have been thinking of that hit for the entire second half.

4. Mishandled Snap. Q2, 00:03.

As the clock was running out of the first half and the Buffalo Bills were on the Miami 34-yard line, Josh Allen stepped under center to spike the ball. This would have given Tyler Bass a 51-yard field goal attempt going into the half.

Unfortunately, with Mitch Morse inactive and backup center Greg Van Roten snapping the ball, Allen did not receive the ball cleanly. It bobbled in his hands, and he threw a simple screen pass to Stefon Diggs instead. Diggs gained 9 yards, but time ran out and the half was over.

By rule, the spike is not considered intentional grounding if it occurs with the quarterback under center and immediately after the snap. It’s a unique provision in the rules, allowing offenses to score in tight timing situations, but it needs to be executed properly. Because of this, by rule, had Allen spiked the ball after a long, bobbled snap, it should have been called intentional grounding. This penalty would have come with a 10-second run off, and the half would have ended.

It’s unclear whether the officials would have called this. They should have, and probably would have, but could it have been worth the risk? Could Allen have thrown it at Diggs’s feet or over his head in less than three seconds? Maybe. But it’s impossible to blame the quarterback for trying to make something happen.

I am astonished that Allen knew the rule, and had the presence of mind to avoid a penalty in the half-second it took to process the play. We all knew he is one of the most talented quarterbacks in the league, but his rules literacy shows he’s probably one of the smartest as well.

5. No call for Holding. Q4, 15:00.

This was the first play of the fourth quarter. On a 2nd and 9, Allen targeted WR Isaiah McKenzie over the middle. The ball was a little high and fell incomplete. Unfortunately, OL Greg Van Roten fell injured on the incompletion, so there was no replay from the CBS broadcast. This is the best view I have of it.

This is defensive pass interference. Like, full stop. The defender held McKenzie both on his break and as the ball arrived. The NFL’s point of emphasis this year is to not miss illegal contact and defensive holding. The league wants to further promote passing in an already pass-friendly game.

Though an important miss, my frustration does not lie specifically with this play, but how officials have consistently ruled on Bills passing plays. Last year, the Buffalo Bills — who pass a LOT — only benefitted from eight defensive pass interference fouls, slightly below the mean of 9.1. But, more importantly, how many defensive holding fouls do you think we benefitted from?

Over the course of the 19-game 2021 season, the answer is one. Now, the Bills declined three defensive holding fouls over the course of the season, but they were dead last in accepted ones. I don’t know whether it’s the style of routes the Bills run. The receivers’ size, perhaps? But it’s becoming a trend that Bills pass-catchers simply do not draw holding fouls. The sample size isn’t small.


Kemp and his crew had an alright game. This might not be something most Buffalo Bills fans wanted or expected to hear, but there have been far worse officiated games throughout the league than this one. Had the Bills made literally one of several crucial plays in the game, this article isn’t remotely controversial.

Buffalo needs to make just one more play, stay out of 100-degree heat, and get their players back and they’ll be fine. And perhaps, benefit from a defensive holding penalty every once in a while. I trust every reader of this article will react like I will when (if?) it happens. A hearty, though sarcastic cheers to the zebras and get right back into the game.

Next week, the Buffalo Bills will play the Baltimore Ravens in what appears to be a tropical storm. There’s potential for weird plays and weird rulings, and hopefully for a Bills win. See you then.

Featured Image: Sam Navarro/USA TODAY Sports

Blake Parnham is a sports official and a die-hard Buffalo Bills fan. Blake is an advocate for reducing the abuse directed at officials in amateur sport. On gameday, you can find him in his backyard at the Bills Helmet Bar, in Keswick, Ontario.