In the NFL, it clearly would've been, no questions asked. From just watching the play live, and the re-play, it appeared clear that that #42 (who hasn't missed too many meals) purposely wanted to make sure his rotund body cemented him into that cold turf. Even when the lard got up, he implanted his chest and used it against Brown's body.
The first game of the NFL season this year when the Browns played the Steelers, Myles Garrett almost sacked Big Ben, but Ben got rid of the ball just a moment sooner. Garrett's body partially landed on top of Ben, which there was really no way to avoid it by the specific angle Garrett was on in route to getting to Ben, and Garrett got flagged for unnecessary roughness.
In comparing the two, last night's was night and day different, with last night's seemingly being considerably more egregious.