A palpably unfair act — a situation where a yardage penalty is insufficient and fair play requires an extraordinary remedy — has never been called in the NFL, although there were a few situations where it could have. It nearly happened in the NFC Championship Game.
On three consecutive attempts to run the famous — or infamous, depending where your loyalties lie — Brotherly Shove, the Eagles could not even snap the ball due to consecutive encroachment fouls by the Commanders in the NFC Championship Game.
The first two were committed by linebacker Frankie Luvu, who leapt over the lineman in a Troy Polamalu-esque attempt to tackle Jalen Hurts as he was receiving the snap. After those first two fouls, referee Shawn Hochuli announced that Washington had been warned that any additional deliberate fouls of this nature would be assessed as an unsportsmanlike conduct.
The third foul was committed by defensive lineman Jonathan Allen. Since it wasn’t intentional, it wasn’t assessed as unsportsmanlike, but Hochuli announced that if this continued, “at some point” he could potentially award a score to Philadelphia.
The next down was a touchdown.
Full sequence of how the latest Jalen Hurts rushing TD went down. pic.twitter.com/VR6ABLgKmh
— NFL (@NFL) January 26, 2025
There have been times it has been called in college for various reasons. A full list can be found here: