Brady Myths: The "Brady Rule" or "You Can't Hit Tom Brady"

David Butler II-USA TODAY Sports

In this edition of Brady Myths we examine the claim that Tom Brady has specifically and unfairly benefited throughout his career from the roughing the passer article added to the rule book prior to the 2009 season.


It is still a heavy play to watch. New England hosted Kansas City Week 1 of the 2008 season on a sunny 1pm game in Foxborough. The Pats were ready to begin their season in their sparkling clean white uniforms. Despite a loss in Super Bowl 42 in the previous season, hopes were high for a return to the Super Bowl as they had maintained nearly all their players from the 2007 undefeated regular season. Most importantly, they still had Tom Brady and Randy Moss - fresh off breaking the single season TD records at their respective positions.

7:38 1st Quarter

NE 0 KC 0 1st & 10 @ KC 43

Brady lines up under center with RB Sammy Morris as a single back. Seconds prior to the snap, S Bernard Pollard jogs down from the KC 30 and stops just behind the LDE at the KC 42. The ball is snapped. Pollard charges thru the line behind the LDE only to be stopped dead in his tracks – completely blown up by Sammy Morris in pass protection after a play action fake. Morris' block takes Pollard the ground as Brady finishes his drop back to the NE 52. Brady looks once toward the middle of the field and then moves onto his second read. Brady takes three steps and fires the ball down the right sideline towards Randy Moss. However, Tom plants his front left foot at the KC 49, while Pollard simultaneously lunges from the ground at the KC 46 - a full three yards - to meet Brady's fully stretched front plant leg. The impact crumples Brady immediately. Moss comes under the double coverage to catch the ball at the NE 18 only to subsequently fumble the ball to KC.

"Kansas City came up with the ball, but that is not the story. Tom Brady took a tremendous hit as he released that ball on his left leg," Dan Dierdorf warned CBS viewers.

And he was right. As soon as that injury happened, the story of the 2008 season for the Patriots was that it was over before it began. The reception didn't matter. The fumble didn't matter. The game didn't matter. Tom Brady had tore his ACL and MCL. Over only 7 minutes and 22 seconds after it started. Over.

2009 Points of Emphasis - Article 11, Section D

Contrary to what some may believe, "roughing the passer" has been in the rulebook since 1938. Therefore the concept of protecting the quarterback from unnecessary and irrelevant physical punishment has long been a tradition of football. An additional subsection of the rule added prior to the 2009 season, pertained only towards intentionally and specifically diving towards a quarterback's knee or ankle area.

Article 11, Section D

"A rushing defender is prohibited from forcibly hitting in the knee area or below a passer who has one or both feet on the ground, even if the initial contact is above the knee. It is not a foul if the defender is blocked (or fouled) into the passer and has no opportunity to avoid him.


A defender cannot initiate a roll or lunge and forcibly hit the passer in the knee area or below, even if he is being contacted by another player.

It is not a foul if the defender swipes or grabs a passer in the knee area or below in an attempt to tackle him provided he does not make forcible contact with the helmet, shoulder, chest, or forearm."

The rule is explained to be essential in cases in which the quarterback is "particularly vulnerable to injury" and was preexisting. The "Notes" section was the only piece added onto a preexisting rule.

*Credit to the observant readers who correctly pointed that out that it was actually Carson Palmer's January 8, 2006 Wild Card Round injury against the Steelers and subsequent rule change prior to the 2006 regular season that laid the groundwork for what is erroneously now known as the "Brady Rule".

David Clark, a Bengals writer, agrees:

Some call the rule designed to protect quarterbacks' knees the "Tom Brady rule," but it was the "Carson Palmer rule" first.

Either way, once the 2009 rule was approved, the outrage was quick and furious. The never-ending debate about the softness of football (and extrapolated to America as a whole) intensified. The vehement hatred of Tom Brady intensified culminating in derisively naming the new RTP article: "the Tom Brady rule" - a rule that was proclaimed to be the end of football.

Even former teammate Rodney Harrison joined in on the action on national TV:

"Tom Brady, if you are listening, take off the skirt and put on some slacks."

(Hard to quantify the insane level of irony in this statement given Harrison's Trent Green preseason incident.)

Those who run on pure hatred for Tom Brady like normal humans run on oxygen were foaming at the mouth for this excuse to explain away his success – thereby rendering his accomplishments meaningless. For the dull and uninformed this was just fuel for one of their favorite accusations:

"Shady" Brady, Bill "Belicheat" and the New England Cheatriots win primarily because they cheat under the permission of the league and help of the referees.

And within this sub-group, there was a new specific claim:

The NFL put in Article 11, Section D in order to award Tom Brady a disproportionate amount of favorable calls to ensure wins.

So was this rule just an excuse by the league to further prop up the New England Dynasty?

Is Tom Brady a whiny baby who gets bailed out by the referees who won't let their precious golden boy get hurt by the big, bad, meanie players from other teams?

The Evidence & Lack Thereof

(Note: any numbers include regular and postseason.)

To begin, it is important to note that a "roughing the passer" call is rarely actually called in an NFL game. From he data available to me from 1994-2019, RTP was called 0.34 times a game ~ or roughly 1 every 3 games. Any league average quarterback was expected to benefit from a call every .17 games overall from 1994-2019 and .19 times per game from 2009-2019. Brady benefited from a RTP call only every .14 games after the infamous rule addition named after him.

To imply that player or team success is solely derived from "getting all the calls" is obviously downright silly. Usually, calls go both ways and the best players overcome.

"Brady Rule" Era of 2009-2017 vs. 2000-2008 Era

Believe it or not, the frequency of RTP calls did not increase after the 2009 rule change. It was the additional 2018 "Rodgers Rule" change coupled by an inflow of "dual-threat" mobile quarterbacks that provided a spike in RTP calls. The 2009 season - in which the rule became a point of emphasis - was the third lowest year (67) for RTP calls from 2000-2019.

1994-1999 RTP 2000-2008 RTP 2009-2017 RTP 2018-2019 RTP
1994 58 2000 75 2009 67 2018 114
1995 45 2001 77 2010 86 2019 134
1996 49 2002 99 2011 99 Total 248
1997 57 2003 107 2012 88 Average 124
1998 64 2004 128 2013 89
1996 66 2005 121 2014 99
Total 339 2006 102 2015 100
Average 56.5 2007 59 2016 85
2008 58 2017 105
Total 826 Total 818
Average 91.78 Average 90.89

So, the truth is that the "Brady Rule" did nothing to increase the frequency of RTP calls but rather smoothed the consistency in which they are called.

Eight consecutive years (2010-2017) RTP was called between 85 and 105 times. The previous 2000-2008 period saw a low of 58, a high of 128, and no consecutive three year period within 22 calls of each other. The "Brady Rule" era saw no such gap. The difference between 2006 to 2007 was a staggering 43 calls (102 to 58) or 57% decline. The increase from 2008 to 2009 only manifested in 9 additional calls (58 to 67). 2007 to 2009 was lowest point of the 21st Century with years of 59, 58, and 67.

Once again, the "Brady Rule" era actually witnessed a decrease in RTP calls – that is prior to the "Rodgers Rule" of 2018.

From 2009-2017 RTP was called 818 times – 90.89 times per year. In the previous nine year period, 2000-2008, RTP was called 828 times – 91.78 times per year. Post-2018 has already seen 248 calls - 124 per year.

2019, alone, holds the all-time high mark of 134 RTP calls.

Yet, in 650 attempts, how many did Tom Brady receive?


First Year of the "Brady Rule" Era

It is true that Tom Brady was the beneficiary of the most RTP calls in 2009. However, 2009 was a stark outlier regarding how Brady's has been officiated in his career in regard to RTP. Was this due to heightened sensitivity regarding quarterback safety? It looks possible as 2009 is the only year in which the league’s star QBs were clustered at the top of the list. Brady was not the only quarterback - star or no-name - to benefit in 2009.

Player 2009 2010 Total
Brady 5 1 6
Fitzpatrick 4 3 7
Cutler 3 5 8
Brees 3 4 7
Rodgers 3 3 6
Roethlisb. 3 1 4
Rivers 3 0 3
Manning 3 0 3
Total 27 17 44

For example, relatively unknown Ryan Fitzpatrick ranked second with 4 RTP calls on only 227 attempts - a rate more than double Brady's 5 on 565 attempts. Also, the top 8 QBs who benefited from RTP in 2009 saw a decreased total of 27 to just 17 in 2010 despite the fact that overall RTP calls increased from 67 to 86. Brady, Rivers, Roethlisberger, and Peyton Manning combined received 2 RTP calls in 2010. Brady, Rivers, Roethlisberger, Manning, and Rodgers combined (5) received only as many RTP calls as Jay Cutler alone in 2010.

In fact, no one has benefited more from RTP since 2009 than NFL vagabond Ryan Fitzpatrick. In 2019, Fitzpatrick started in only 13 games yet led the league with an astonishing TEN roughing the passer calls received. Again, Brady received zero in 650 pass attempts and 17 games. Shouldn’t it then be named "Fitzpatrick Rule"? Or what of mediocre, under-performing Jay Cutler who finished 3rd in 2009, 2nd in 2010, 2nd in 2011, and 2nd again in 2017? Cutler was second in RTP since 2009 at the end of his last year in 2017. He is still fourth. Does the "Fitzpatrick-Cutler Rule" have a nice ring to you?

Due to his proclivity for racking up RTP calls, the website from which this data was accessed has anointed Ryan Fitzpatrick as: "He-Who-Cannot-Be-Touched"

Tom Brady RTP Rankings By Season 2009-2019

Year Rank RTP
2009 1 5
2010 t-14 1
2011 t-20 1
2012 t-18 2
2013 t-11 2
2014 t-15 2
2015 t-2 5
2016 t-8 3
2017 t-10 3
2018 t-7 4
2019 t-22 0
2009-2019 9 28
Average 11.6 2.55

The inconsistencies to the "you can’t breathe on Brady" narrative continued to fray as the years went on. Tom ranked in various places in regards to overall RTP received. However, overall RTP is not the best framework to in understanding how Brady has been officiated as it does not account for factors such as the amount of games a player plays or how many times they are dropping back to pass. You can't be the beneficiary of a "roughing the passer" penalty if you do not drop back to pass.

RTP QB Rankings 2009-2019 (min 40 games)

Rank Player Total Player Per G Player Per100Att Player Per Sk Player 3rd D %
1 Fitzpatrick 50 Fitzpatrick 0.36 Griffin 1.25 Fitzpatrick 0.207 Henne 75.0
2 Ryan 39 McCown 0.35 McCown 1.18 Wentz 0.137 Hasselbeck 62.5
3 Rodgers 31 Wentz 0.32 Fitzpatrick 1.17 McCown 0.128 Carr 58.3
4 Newton 30 Griffin 0.31 Vick 0.92 Trubisky 0.126 Trubisky 50.0
5 Cutler 30 Trubisky 0.29 Trubisky 0.91 Foles 0.126 Moore 50.0
6 Brees 29 Watson 0.29 Watson 0.9 Griffin 0.123 Rodgers 45.2
7 Stafford 29 Bradford 0.29 Wentz 0.87 Bradford 0.122 Dalton 45.0
8 Wilson 29 Cutler 0.25 Mariota 0.82 Cousins 0.115 Taylor 42.9
9 Brady 28 Cousins 0.23 Bradford 0.81 Cutler 0.108 Romo 42.9
10 Palmer 26 Newton 0.23 Cutler 0.8 Palmer 0.108 McCown 42.1
11 Bradford 24 Mariota 0.23 Newton 0.71 Vick 0.105 Watson 41.7
12 Tannehill 23 Tannehill 0.23 Tannehill 0.71 Ryan 0.105 Brees 41.4
13 Smith 23 Vick 0.23 Wilson 0.69 Goff 0.105 Stafford 41.4
14 Cousins 22 Palmer 0.22 Foles 0.68 Orton 0.103 Cousins 40.9
15 Roethlisb. 22 Foles 0.21 Cousins 0.67 Brees 0.098 Campbell 40.0
16 Flacco 22 Ryan 0.21 Palmer 0.61 Keenum 0.096 Freeman 40.0
17 Dalton 20 Orton 0.21 Orton 0.61 Newton 0.095 Foles 38.5
18 Rivers 20 Goff 0.21 Prescott 0.6 Prescott 0.092 Griffin 37.5
19 McCown 19 Wilson 0.2 Goff 0.59 Luck 0.091 Bradford 37.5
20 Wentz 18 Stafford 0.19 Ryan 0.58 Mariota 0.09 Keenum 33.3
21 Luck 17 Prescott 0.19 Keenum 0.55 Watson 0.086 Schaub 33.3
22 Manning E 17 Rodgers 0.18 Smith 0.52 Brady 0.084 Bortles 33.3
23 Griffin 16 Keenum 0.18 Rodgers 0.51 Tannehill 0.082 Wilson 31.0
24 Mariota 15 Luck 0.18 Winston 0.51 Stafford 0.081 Palmer 30.8
25 Vick 14 Winston 0.18 Stafford 0.5 Winston 0.076 Newton 30.0
26 Foles 13 Brees 0.16 Taylor 0.5 Wilson 0.074 Rivers 30.0
27 Prescott 13 Smith 0.16 Luck 0.47 Carr 0.07 Luck 29.4
28 Winston 13 Dalton 0.15 Gabbert 0.47 Rodgers 0.069 Manning E 29.4
29 Carr 12 Bortles 0.15 Bortles 0.44 Hasselbeck 0.069 Brady 28.6
30 Trubisky 12 Brady 0.14 Dalton 0.43 Schaub 0.069 Ryan 28.2
31 Watson 12 Roethlisb. 0.14 Brees 0.41 Dalton 0.068 Wentz 27.8
32 Keenum 12 Henne 0.13 Henne 0.41 Smith 0.067 Orton 27.3
33 Bortles 12 Carr 0.13 Hoyer 0.4 Hoyer 0.067 Cutler 26.7
34 Goff 12 Flacco 0.13 Moore 0.4 Roethlisb. 0.064 Mariota 26.7
35 Orton 11 Gabbert 0.13 Roethlisb. 0.39 Flacco 0.062 Tannehill 26.1
36 Schaub 9 Hasselbeck 0.12 Hasselbeck 0.39 Bortles 0.06 Smith 26.1
37 Sanchez 9 Taylor 0.12 Brady 0.38 Manning E 0.055 Prescott 23.1
38 Henne 8 Schaub 0.11 Flacco 0.37 Henne 0.053 Roethlisb. 22.7
39 Hasselbeck 8 Rivers 0.11 Cassel 0.37 Rivers 0.053 Flacco 22.7
40 Cassel 8 Sanchez 0.11 Carr 0.36 Sanchez 0.052 Sanchez 22.2
41 Taylor 7 Hoyer 0.11 Sanchez 0.36 Gabbert 0.051 Fitzpatrick 22.0
42 Romo 7 Cassel 0.11 Campbell 0.36 Taylor 0.049 Vick 21.4
43 Gabbert 7 Campbell 0.1 Schaub 0.35 Cassel 0.049 Manning 20.0
44 Kaepernick 6 Manning E 0.1 Rivers 0.32 Campbell 0.048 Kaepernick 16.7
45 Hoyer 6 Moore 0.09 Kaepernick 0.32 Moore 0.047 Winston 15.4
46 Campbell 5 Romo 0.08 Manning E 0.28 Freeman 0.045 Goff 8.3
47 Freeman 5 Freeman 0.08 Freeman 0.24 Manning 0.042 Hoyer 0.0
48 Manning 5 Kaepernick 0.08 Romo 0.22 Romo 0.034 Gabbert 0.0
49 Moore 4 Manning 0.05 Osweiler 0.16 Kaepernick 0.033 Cassel 0.0
50 Osweiler 2 Osweiler 0.05 Manning 0.13 Osweiler 0.024 Osweiler 0.0

Many insights can be garnered from this.

First, Tom Brady has received significantly less RTP calls than league average and backup quarterbacks.

Second, if anything, the RTP rule additions in 2009 and 2018 haven’t incentivized passing. The increase in passing stats in the past decade and a half you can attribute more heavily to the "Ty Law" rule - which for logical consistency should be called the "Peyton Manning Rule".

The RTP rule additions of both 2009 and 2018 have helped quarterbacks who run, not those who pass. Referees are prone to feel sympathy for a quarterback who gets tackled regardless of whether they are considered a "runner" or not. Referees are human and they tend to treat quarterbacks on the run like the guy you can’t hit because he wears glasses.

A close look at the list shows that, the rule has not benefited those it was said to protect: stationary, statuesque pocket passers quarterbacks but rather the opposite: mobile and running prone "dual-threat" quarterbacks.

Look at the names towards the top of the list: Griffin, Fitzpatrick, Vick, Trubisky, Watson, Wentz, Mariota, Newton, Tannehill, Wilson - all QBs prone to taking off down field.

In terms of RTP call per 100 pass attempt, only Sam Bradford out of the top 13 players averaged less than 9.5 rushing yards per game from 2009-2019. 21 of the top 30 players hit this mark. Just 2 of the bottom 20 met this mark. That bottom twenty includes a denser set of star QBs such as Drew Brees, Ben Roethlisberger, Tom Brady, Phillip Rivers, Joe Flacco, Eli Manning, Tony Romo, and Peyton Manning . . .

Due to this information, I would argue that article 11 in 2009 has done nothing to significantly & specifically benefit star QBs. There seems to be no correlation between star QB and RTP calls whatsoever. The only correlation seems to be between play style and RTP calls.

Well, so far, none of this really fits the narrative.

Look further and it only continues to unravel.

Tom Brady Expected vs. Actual RTP Calls

Per Game Per Pass Attempts
Year Act Exp Diff Exp Diff
2009 5 2.21 2.79 2.37 2.63
2010 1 2.89 -1.89 2.64 -1.64
2011 1 3.71 -2.71 4.08 -3.08
2012 2 3.06 -1.06 3.61 -1.61
2013 2 3.15 -1.15 3.68 -1.68
2014 2 3.71 -1.71 3.95 -1.95
2015 5 3.51 1.49 3.93 1.07
2016 3 2.48 0.53 2.63 0.37
2017 3 3.90 -0.90 4.29 -1.29
2018 4 4.28 -0.28 4.45 -0.45
2019 0 4.42 -4.42 4.92 -4.92
2009-2019 28 37.30 -9.30 40.34 -12.34
Average 2.55 3.39 -0.85 3.66 -1.12

In the effort to illustrate the difference between perception and reality, I compared the amount of RTP calls Tom has received compared to the league average in terms of RTP per game and RTP per 100 pass attempts. I simply multiplied the games he played in a given year times the league average per game and likewise the attempts he threw in that a given year times the league average per 100 attempts thrown.

Brady has actually benefited from 9.3 less RTP calls than expected compared to the league average per game. When accounting for and comparing to the league average number of pass attempts, this number increases to 12.3 less RTP than expected since 2009. This means he has had received roughly one less call per year than he should have expected to receive.

Tom Brady RTP Summary 2009-2019

Category Rank Value
Games 1 196
Att 1 7368
Total RTP 9 28
Per Sack 22 0.084
3rd % 29 0.286
Per Game 31 0.14
Per 100 Att 37 0.38

This table is all you need to see that Brady has in no significant way benefited from the rule in which was named after him.

Overall, Brady receives a RTP call every 7.14 games, every 263.16 attempts, and every 11.9 sacks. He must receive 3.5 RTP calls for a RTP call to occur on 3rd down.

While he ranks in the top 10 in RTP calls received since 2009, he accumulated those by playing in the most games and attempting the most passes. In terms of rate statistics, he is treated rather unfavorably compared to league averages. Only 28.6% of his RTP calls occur on 3rd down (good for a 29th ranking) - meaning that Brady is NOT being bailed out to extend drives.

The brutal truth is that Tom Brady receives a RTP call per pass attempt at a frequency so low - that if RTP were a way to gauge star power and favoritism in the NFL - they would be treating him as the 5th best backup in the league - let alone their golden boy star QB.

The Verdict

While it was true that Tom Brady lead the league in RTP in 2009, that same year Ryan Fitzpatrick outpaced him by twice as much on a per pass basis - so take what you want from that. Additionally, in 2009 it was true that many of the star QBs benefited from RTP. It is the one year that we see all the star QBs clustered towards the top.

After that year, Brady had only two more seasons out of nine in which he had calls above what was expected by league average. It is safe to say that In the cumulative years after 2009, he has not benefited from the rule change since its implementation.

In fact, the complete opposite holds more weight.

Brady has received 12.3 less RTP calls than would be expected since 2009. The incredibly low amount of calls in his favor begs the question as to why it is that Tom Brady DOESN'T benefit from a rule he was said to create.

If any correlation exists between RTP and QB it tends to be running type quarterbacks - NOT pocket passer types.

So, the RTP was obviously not to specifically help the Patriots. It wasn't to necessarily favor offenses. It wasn't a political agenda to weaken football. It was to keep you watching by protecting all of their QBs - not just Tom Brady.

The true reason for the rule is the same reason for why a business makes just about any decision: money.

Regarding unnecessary QB injuries, Robert Kraft said it best:

"It's not good for the league. It's like going to see a great movie and the star isn't in the movie. It's the same principle."

From Joe Namath to Joe Montana to Tom Brady to Patrick Mahomes – quarterbacks are the NFL’s movie stars.

Certain individual QB's due seem more likely to pick up RTP - it just isn't necessarily star QBs. Since 2009, the NFL seems to have called RTP fairly evenly and consistently as star QBs are scattered throughout the distribution and the amount of times per year it was called was stable. (At least until 2018's "Aaron Rodgers Rule".)

A Final Word From Tom Brady

Next time you hear the brain-dead phrase that starts "If that was Tom Brady . . . that defensive player would be fined, suspended, banned, arrested, ect . . ", Look at them and tell them. No. You are wrong, completely & woefully ignorant. Use what you learned in this article and laugh in their face.

Case In Point:

Josh Allen took a hit from Jonathon Jones in week 4 of the 2019 season that knocked him out of the game. Bills players then accused the referees of foregoing preferential treatment for Allen that is reserved for Brady.

Micah Hyde, playing the role of the over-confident ignoramus who speaks a lot and thinks very little, explained his asinine, unthinking stream of consciousness to reporters:

"That's the first thing that came out of my mouth on the sideline: If one of us did that to 12, we wouldn't have been in the game anymore."
Well, Hyde can you repeat the lie and hope it becomes truth - but to do that you first must disregard the cold hard fact that Brady received ZERO RTP calls (17 games, 650 pass attempts) while your QB, Allen, received FIVE (17 games, 507 attempts) in 2019.

In his response, Brady pointed out that no, the player would not have been ejected – because the big hit would never have occurred. Brady is simply not stupid enough to put himself in the situation:

"Actually, I had a play like that in Buffalo early in my career where I was scrambling down the right side and tried to hold on to the ball. I tried to slide late and a guy hit me and my helmet flew about 10 yards away. It kind of riled up their whole sideline. I remember the next day coach (Bill) Belichick said to me -- I'll never forget this -- he said, 'Hey Brady, if you want to have a career in this league, when you're running like that, you either throw the ball away or you slide.' I'll never forget coach Belichick telling me that.

"I've kind of taken to that. A lot of quarterbacks who do run, you're trying to make yards and it's great, and at the same time you're susceptible to big hits. Whether it's a flag or not, or whether it's a penalty, a lot of the rules have changed over the years. But from a quarterback standpoint, I feel like it's always best to try to be available to the team, and take risk/reward and so forth. Again, nobody likes to see anyone get hurt out there. From my own experience, I try to the best I can to avoid any big shots like that."

There you have it from the man himself.

The reason Brady doesn’t get RTP calls is because he doesn’t allow the defense the opportunity to hit him hard enough to receive one.

The reason you "can't hit Tom Brady" is his supernatural awareness and pocket presence - not some NFL directed referee conspiracy.

Please, please save the world of your ignorance and stop cursing Tom Brady every time RTP is called.

If anything, curse Ryan Fitzpatrick.

But logic isn't as fun as blindly hating on Tom Brady is it?

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