NFL to Give Out Punishment Decision After Rams, C.J. Gardner-Johnson Incident

Josh Allen and the Buffalo Bills needed overtime to get past the Los Angeles Rams, 37-34, on Monday night at SoFi Stadium, with kicker Tyler Bass ending it on a 45-yard field goal. The Bills quarterback finished with 210 passing yards and a touchdown through the air, and he added 121 yards and another score on the ground.

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Across the field, Matthew Stafford put up even bigger passing numbers for the Rams, completing 40 of 54 passes for 383 yards and three touchdowns in a losing effort. Even so, the Rams could not close it out before overtime, and the Bills improved to 4-1.

Not everything from the night ended with the final score, though. A defensive play late in the second quarter involving safety C.J. Gardner-Johnson has left the Bills with a question that the win did not answer, and it traces back to a flag thrown with the Rams driving near midfield.

With 2:26 left before halftime, the Rams faced second-and-16 from their own 41-yard line when Stafford’s short pass toward tight end Tyler Higbee fell incomplete. The Buffalo safety then delivered a helmet-to-helmet hit on the defenseless Higbee, drawing an unnecessary roughness flag.

The 15-yard penalty moved Los Angeles to the Buffalo 44, but the drive ended in a punt. The league’s 2026 fine schedule lists $17,911 for a first offense of hitting a defenseless player and $23,882 for a repeat.

CJ Gardner-Johnson absolutely rocks Higbee as he catches this ball. Refs threw a flag for a personal foul for hitting the head of Higbee. pic.twitter.com/DQI171KLTj

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— Rate the Refs (@Rate_the_Refs) October 13, 2026

The Buffalo defender already has an $11,194 fine from a hip-drop tackle against Detroit in Week 2, and both fouls fall under the NFL’s five emphasized player-safety categories.

Another fine would end any partial refund and require a meeting with league officials and his coaches, while a suspension would only become possible after three such fouls.

Gardner-Johnson, in his first season with Buffalo, has 25 combined tackles, one interception and two passes defensed through five games, including seven tackles against the Rams. He also allowed a touchdown to Davante Adams and briefly left Monday’s game with a lower-body injury before returning.

The Bills will visit the Las Vegas Raiders on Sunday at Allegiant Stadium, with kickoff set for 4:25 p.m. ET.

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This story was originally published October 13, 2026 at 5:04 AM.

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