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2022 Buffalo Bills penalty predictions

What does the data say?

Sure, there are lots of conversations on Josh Allen, scoring points, Von Miller, Matt Araiza, etc. And those stories are...fine. I know what everyone reeeeeaaaaaally wants to know about though. So let’s dive right into some penalty predictions for the 2022 Buffalo Bills season.

The 2021 Buffalo Bills

The 2021 Buffalo Bills finished the season with 146 penalties (119 accepted). That was the fifth most in the league, but to be fair they played a couple more games than some other teams. When adjusted per game, they had the ninth-highest rate of penalties per game. According to my rule of four, that just barely makes the cut into “average” territory.

Now that we have some context for where they fell last season, let’s look at a couple of factors to try and make educated guesses on where they might fall this coming season. Some of my earliest work on penalties sought to answer if penalties were more attributable to players or coaching. The answer was that both can have a significant impact.


For this exercise, we’re going to [gasp] mostly ignore Penalty Harm. While I think that Harm does a pretty good job creating relative values to how impactful a penalty was, I don’t think there’s any reason to believe a player might be significantly more prone to say, third-down penalties—which would of course raise their relative harm ranking. Harm is more likely a matter of circumstance than any sort of recklessness. Here’s a chart.

I stuck to players with four or more penalties tossed their way in 2021. There’s some color coding above, which will help us on our journey. The grayed out players are no longer on the team. The bright blue players are still here. For the most part, I think they’ll all be in similar roles too.

That makes things a bit easier. Of the frequent-fliers list, they’re nearly all intact—which should lead to some stability. For the three who are gone, Levi Wallace will likely be replaced by Kaiir Elam who we don’t have any NFL data on yet. If Dane Jackson somehow wins out, there’s likely not a major change from Wallace. Corners are also usually pretty high on the list, so any change is unlikely to make this drop.

Emmanuel Sanders is somewhat remarkable as receivers are not usually this high on the list. It’s possible that the next man up will reduce this by a few. Especially if Gabriel Davis eats up some of those lost snaps. Note that he’s not on the list.

Jerry Hughes’s snaps will likely end up with Von Miller. Miller had three flags last year. He had eight in 2019 (and was on injured reserve in 2020). In other words, Miller could go either way. Which, for the record, most players do fluctuate some.

Coaching/Team stability

Another chart!

This one is pretty straightforward. We know the coaching staff has attempted a few things to cut down on penalties, like having the defensive backs practice in oven mitts. As the chart shows, these measures have been largely ineffective.

Despite turning over the entire roster except Reid Ferguson since taking over, head coach Sean McDermott’s version of the Buffalo Bills have been pretty steady when it comes to most penalty metrics. Arguably his best year was with the roster he mostly inherited and before The Process had time to catch on.

Best Guess

The Bills have pretty consistently yo-yo’d around the average you see above with Sean McDermott at the helm and there’s really no reason to think that changes in 2022. Maybe offensive coordinator Ken Dorsey or offensive line coach Aaron Kromer will do something so drastically different it makes a big impact, but I’m not holding my breath.

On the players’ side of things, there’s not a ton of roster turnover that should make an impact. I didn’t tally things above, but even if the swaps noted pan out as expected it’s a wash. Davis might cut things down by a few, but Miller may just as easily add those flags right back in.

Trend wise the expectation would be to pull back to their average after one of their worst years and that’s a reasonable guess. I won’t go so far as to say they’ll fall below their average. While I said Dorsey and Kromer aren’t likely to cause a “big impact,” I think some impact is probable. Offensive lineman are heavily penalized and there might be some growing pains. My best guess is a slight reduction toward the average numbers, but not quite reaching them.