Crown of the helmet and defenseless are different rules.
Problem for a lot of ball carriers is lowering the head to take the shot. It can look like spearing.
The term "spearing" was removed from the rule book in 2009. But back to the issue. Should we be reading the rule as:
Targeting and Making Forcible Contact
With the Crown of the HelmetARTICLE 3. No player shall target and make forcible contact against an opponent with the crown of his helmet. This foul requires that there be at least one indicator of targeting (See Note 1 below). When in question, it is a foul. (Rule 9-6) (A.R. 9-1-3-I)
Note 1: “Targeting” means that a player takes aim at an opponent for purposes of attacking with forcible contact that goes beyond making a legal tackle or a legal block or playing the ball. Some indicators of targeting include but are not limited to:
• Launch—a player leaving his feet to attack an opponent by an upward and forward thrust of the body to make forcible contact in the head or neck area
• A crouch followed by an upward and forward thrust to attack with forcible contact at the head or neck area, even though one or both feet are still on the ground
• Leading with helmet, shoulder, forearm, fist, hand or elbow to attack with forcible contact at the head or neck area
• Lowering the head before attacking by initiating forcible contact with the crown of the helmet
If we read Article 3 as written and continue with Note 1 then there is no requirement that the "target" be defenseless. So can't we potentially have a targeting call without a defenseless requirement? And if yes, then can't we have a flag for a runner clearly lowering his helmet and blasting a defensive back with the crown? The equivalent of the pre-2009 spearing call?