It was actually called a number of years ago in a Bills game. I don't remember the year -- I think probably 1988 or 1989, and I don't remember but it might have been against the Dolphins. If I recall correctly, Jim Kelly was hit and fumbled the ball, but the defender was penalized when he grabbed Kelly and prevented him from going after the ball. It's a little hazy now, but I remember hearing the call and I couldn't believe it. It's the only time I've ever heard that call made.