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Through 10 weeks of play, NFL officials had issued a grand total of 20 intentional grounding penalties. Most of us know it when we see it -- a quarterback desperately throwing the ball away simply to avoid a sack -- and calls appear reserved for the most egregious instances.

That is why Walt Coleman's call Thursday night against Buffalo Bills quarterback Kyle Orton stood out. It's true that Orton was under a heavy rush from Miami Dolphins defensive end Olivier Vernon, and his throw toward the left sideline wasn't close to a completion. But receiver Sammy Watkins was working in the general area, breaking back late toward the sideline after initially making a move inside.

The ball landed just out of bounds at the 23-yard line. At that moment, Watkins was at the 27, roughly 10 yards from the sideline. So the ball was about four yards short and 10 yards wide of him.

Is that enough to infer intentional grounding? Here's how the NFL rule book explains the penalty for quarterbacks who are in the pocket, as Orton was: "It is a foul for intentional grounding if a passer, facing an imminent loss of yardage because of pressure from the defense, throws a forward pass without a realistic chance of completion. A realistic chance of completion is defined as a pass that lands in the direction and the vicinity of an originally eligible receiver."

In this case, there can be little argument that Watkins was in the vicinity of the ball. The question is whether Orton threw in the direction Watkins was running. It is a complicated issue requiring an understanding of route structure and timing that few outside the Bills' offensive huddle would know. Was Watkins running a double-move that Orton couldn't wait on? (Orton broke toward the sideline after the ball was thrown.) Did Watkins run the wrong route, crossing up Orton?

Former NFL official Mike Carey said on the CBS broadcast that officials can't take into account the possibility of a "mis-route" and can only judge what they see. Still, quarterbacks routinely throw passes before the final break of a route. It seems more than reasonable for intentional grounding to be reserved for obvious cases when the quarterback unloads the ball into an entirely empty area.

That did not seem to be the case Thursday night. But after a lengthy discussion, Coleman issued the penalty. Because Orton threw from the end zone, it resulted in a safety and a major turning point in the game.

It was just the second intentional grounding call from Coleman's crew this season. Pete Morelli's crew leads the NFL with three such calls, while three crews -- those of Clete Blakeman, Terry McAulay and Craig Wrolstad -- haven't called one yet.

Note: As always, the bar graph at the top of this post documents the per-game frequency of all penalty calls this season, by crew. Carl Cheffers' crew continues to be the most active, with more than 20 penalties per game.