NFL Rule 3, Section 22, Article 2, Note 2 says: "When (an offensive) player is holding the ball to pass it forward, any intentional forward movement of his hand starts a forward pass, even if the player losses possession of the ball as he is attempting to tuck it back toward his body. Also, if the player has tucked the ball into his body and then loses possession, it is a fumble." Never has that distinction between "attempting to tuck" and "has tucked" been more controversial than in the 2002 AFC divisional playoff game between the Patriots and the Oakland Raiders. With the Patriots driving toward a game-tying field goal, cornerback Charles Woodson knocked the ball from Brady's hands, and linebacker Greg Biekert recovered it. The game-sealing fumble was overturned however, when upon review the referees ruled that Brady was still in the process of tucking the ball even though it had already made contact with his non-throwing, left hand. The Patriots won the game in overtime, while the Raiders fumed.
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