Doesn't have to be a hit to the head, If the receiver cannot protect themselves it gets called. Just ask Eric Smith
I was mistaken, it has to be a hit to the head or neck of the receiver or the tackler has to hit with the crown of the helmet. Both of Smiths were to the head though. Still doesn't look like the play in question would have warranted the call at all. It was not to Hills head or neck and Polamalu did not lead with the top of his helmet from what I see.
Landry was great for the Jets. the only reason he was allowed to walk away was money, we didn't have any.