Robert "Bubba" Pena (born August 8, 1949) is a former National Football League (NFL) offensive lineman who played four seasons with the Cleveland Browns from 1971 to 1974.

After the 1968 season, Pena decided to play football with the University of Massachusetts Amherst Redmen (now called Minutemen) for his remaining two years of collegiate eligibility.

However, there was a contract dispute between Browns owner Art Modell and Pena, hindering his ability to start for the team.

Pena contemplated quitting football altogether after the injury, but Modell convinced him to stay and promised him a starting spot the following year.

Pena was named to the 1972 All-Rookie team, as he was eligible because of the amount of time he missed in the prior season.

This situation in the prison made it impossible to follow social distancing guidelines, which prompted Pena, who was in a highly susceptible demographic, to file the motion.