Referee: Brady drew flag for using 'abusive language'
Referee Shawn Hochuli defended the decision, which caused controversy as Miller appeared to lead with his helmet, leaving Brady bleeding from his lower lip.
"He got in my face in an aggressive manner and used abusive language," Hochuli said. "As for the hit, we did not think that it rose to the level of roughing the passer."
Brady admitted last week that officials "probably let me get away with a lot of unsportsmanlike conducts - talking smack to the other teams and talking smack to the refs when I don't think I get the right call."
But as the hit came after the ball hit the ground, the penalty yardage was assessed from the spot where the Rams were slated to take over possession after the turnover on downs.
Hochuli said there was no interpretation for the rule.
"By rule, in a defenseless receiver hit like that, we treat it as a post-possession foul," he said. "It's a dead-ball foul, and it's enforced from the succeeding spot."