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The same exact scenario (inside the 20) happened a few years ago in the PAC-12 and I believe they addressed it as the officials just need to use common sense and judge the intent of the hold - holding an eligible receiver would result in auto first down. Holding a player from making a block on...

And if anyone did remember one it would be on a defensive player holding a player from making a block, not on a DB holding an eligible receiver.

Holding was against an "eligible receiver" and you cannot define that play as a "rushing play". Complete trash.