Buffalo Bills safety C.J. Gardner-Johnson was ejected Sunday for spitting toward Las Vegas Raiders tight end Brock Bowers, all but guaranteeing some form of punishment from the NFL. But what will that punishment be? The NFL’s unfortunate history of spitting incidents may give some clues.
A 2025 NFL standard turned spitting from a fines-only offense into a game-missing penalty.
Officials disqualified Gardner-Johnson for unsportsmanlike conduct after video showed him spinning and spitting toward Bowers’ area, according to NFL Network insider Ian Rapoport. Broadcast cameras captured the moment too, according to the NFL on CBS broadcast account.
His disciplinary file runs long. The Athletic put his career fines at roughly $195,000 across 13 to 15 incidents, covering taunting, late hits and unnecessary roughness. In December 2024, he was ejected against Washington for taunting twice, according to CBS Sports. He was fined $45,022 for those penalties, according to NJ.com. Peers also voted him the NFL’s top trash-talker, according to the Democrat and Chronicle. Reports on his career do not show a suspension for on-field conduct.
NFL Spitting Discipline History Before Gardner-Johnson Incident
Denver Broncos linebacker Bill Romanowski spat in San Francisco 49ers receiver J.J. Stokes’ face in December 1997. Romanowski drew a $7,500 fine, plus a strongly worded letter, according to The Washington Post. He apologized.
Washington Redskins safety Sean Taylor was ejected from a January 2006 playoff game against the Tampa Bay Buccaneers for spitting at running back Michael Pittman. Taylor was fined $17,000, not suspended, according to The Washington Post. The amount matched his playoff bonus, and he kept his place for the following week.
Dallas Cowboys receiver Terrell Owens spat in Atlanta Falcons cornerback DeAngelo Hall’s face that December. Officials missed it, but Owens received a $35,000 fine, according to Reuters.
Baltimore Ravens cornerback Marcus Peters appeared to spit toward Cleveland Browns receiver Jarvis Landry in December 2020. Peters was fined $12,500 for unsportsmanlike conduct, according to The Associated Press. He denied spitting and appealed.
Pittsburgh Steelers guard Trai Turner was ejected against the Raiders in September 2021 after appearing to spit toward Las Vegas players following a touchdown. Turner said he was spat on first, according to CBS Sports. Turner was fined $15,450 for unsportsmanlike conduct, according to Steelers Now.
Raiders defensive end Maxx Crosby, who denied spitting, was fined $6,971 and appealed, according to NFL.com.
New Orleans Saints defensive end Payton Turner faced an allegation in September 2024 that he spat toward concussed Eagles receiver DeVonta Smith. “Y’all reaching,” Turner said, according to The Athletic reporting on the allegation. Coverage of the episode shows no fine or suspension. Older cases, including Regan Upshaw’s fine of roughly $29,000 around 2000, followed the same pattern.
The league changed course in 2025. Philadelphia Eagles tackle Jalen Carter spat on Dallas quarterback Dak Prescott after the opening kickoff on Sept. 4 and was ejected. His ejection served as a one-game suspension, according to ESPN, and he forfeited a game check of about $57,222. The NFL announced a new standard for spitting punishment, according to Pro Football Talk.
Cincinnati Bengals receiver Ja’Marr Chase spat on Pittsburgh cornerback Jalen Ramsey in November 2025, and Ramsey answered with a punch and an ejection. Chase was suspended one game for spitting, according to ESPN, a penalty that cost him roughly $448,000 to $507,000. A hearing officer upheld Chase’s suspension, according to Pro Football Talk. The league told players they are “on clear notice” that spitting means a one-game suspension and a lost game check, according to Pro Football Talk.
Buffalo Bills’ C.J. Gardner-Johnson Suspension Outlook
Spitting at an opponent falls under Rule 12, Section 3, Article 1 of the league rulebook, which governs conduct that violates sportsmanship. None of the pre-2025 cases above ended in a suspension. Both 2025 cases cost a player one game’s pay.
The league can apply either route to Gardner-Johnson — a formal one-game suspension, or the ejection counted as time served alongside a fine near the size of a game check. His history of fines and a prior ejection gives the league additional conduct to review.
The NFL reviews video and official reports before ruling, usually within days, and fines typically are posted publicly on Saturday. If the league confirms the spitting seen on video, Gardner-Johnson would be the third player in two seasons to lose a game over it.
NFL Spitting History Offers Clues on Bills’ C.J. Gardner-Johnson Punishment