People keep saying that. I don't understand why. This is the rule in question:
https://operations.nfl.com/the-rules/nfl-video-rulebook/roughing-
"In covering the passer position, Referees will be particularly alert to fouls in which defenders impermissibly use the helmet and/or facemask to hit the passer, or
use hands, arms, or other parts of the body to hit the passer forcibly in the head or neck area (see also the other unnecessary roughness rules covering these subjects)."
Here is the hit:
https://youtu.be/8SRk1XkFkhU
Remember, it's head or neck
area. Not just head or neck, otherwise there'd be no need for the added word. Can anyone possibly imagine why, after the last couple of years, clubbing a QB in the collarbone would be disallowed and a point of emphasis? (*cough*AR*cough*)
He deliberately used his arm to forcibly club the QB in the head or neck area. The hit is definitionally roughing the passer, and was called correctly. We may not like the rules which baby the QB, but they are what they are. It may be a bad rule, but that was not a bad call.
If you want to talk about a penalty that should not have been called, how about that pass interference on Jackson which at most should have been an illegal contact, and was an uncatchable ball?