[3] An early example of an unfair act (though such a rule was not yet codified) occurred on November 23, 1918, when Navy faced the powerful Great Lakes NTS team.
[citation needed] In 2022, the NFL threatened to use the unfair act clause against the Buffalo Bills when fans at Highmark Stadium bombarded the field with snowballs during a December 17 game against the Miami Dolphins.
Because referee Bill Vinovich arbitrarily threatened a 15-yard unsportsmanlike conduct penalty if the snowball throwing continued, The Buffalo News argued, based on a precedent following a similar situation in 1985 between the San Francisco 49ers and Denver Broncos when a snowball hurled during an extra point attempt hit 49ers holder Matt Cavanaugh and allowed the Broncos to tackle him before the kick was attempted, that Vinovich had acted outside the bounds of the NFL rulebook when making the threat.
[6] On November 6, 2016, near the end of the first half, the San Francisco 49ers deliberately held pass receivers, forcing the New Orleans Saints to settle for a short field goal.
Before the score, grounds crew member Mark Henderson (a convicted burglar on a weekend furlough from Walpole State Prison) plowed a special path for placekicker John Smith to make the kick easier.
[11] In the first test of the rule, on October 21, 2019, it went unenforced, as the New England Patriots committed repeated dead-ball penalties (which their opponent New York Jets declined) and ran out nearly a minute of game clock without being penalized.
Former Patriot player and Tennessee Titan head coach, Mike Vrabel, had his team commit various penalties to run 50 seconds off the clock in the final quarter of the game.
On a key drive late in the 2018 NFC Championship Game, Nickell Robey-Coleman of the Los Angeles Rams made a helmet-to-helmet hit that constituted pass interference.
During the 2024 NFC Championship Game, the Washington Commanders committed three encroachment penalties in a row defending the goal line, in an attempt to thwart the Philadelphia Eagles' signature quarterback sneak, the "tush push."
Following the third penalty, referee Shawn Hochuli warned the Commanders that further encroachments would result in the awarding of a score to the Eagles per the palpably unfair act rule.