Cam Newton was under pressure in the pocket, spun out, and went head first right into Dan Skuta coming around the end. One could try to argue that Newton was turning into a runner, but the rule requires a penalty on a helmet hit on a defenseless player, which includes a quarterback in the pocket. Certainly not the type of play where Skuta had much chance to avoid it.
Jim Harbaugh was, amazingly, not thrilled with the call. It didn’t matter, as Newton was intercepted a few plays later and San Francisco appears to be heading to the NFC Championship Game.
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