It would have been easy for the Browns to avoid the personal foul penalty at the end of the first half that gave the Jets a field goal try. That try, you will remember, was converted so the Jets could tie it up at 10 after going scoreless for all but the last two minutes or so of the first half. The Browns could have avoided that penalty by just not touching the Jets’ QB as he ran out of bounds. That would have been too easy. Whether or not it was a penalty is also not without doubt though after you see this replay of the giant flop.
It’s also noteworthy that the official closest to the play recognized the flop and was standing his ground that it wasn’t a penalty. The other official flew in from further away, possibly influenced by Rex Ryan’s enormous hissy-fit, to throw the flag for fifteen.
There’s very little doubt that this activity would draw a fine in the NBA where it’s illegal to trick referees and make them look stupid by flopping.