I've seen that called only once as intentional grounding. It was called against the Jets. Seriously. You can't make this stuff up. I think the receiver going downfield tripped/fell, so the ball had to be in the air. Refs called the Jets for intentional grounding.
It's ridiculous. We're not even talking subtle stuff where the hands are inside under the pads, we're talking Jets D-linemen getting roped down, or held back like an fighting angry woman during a domestic violence call on "Cops".