In 1997, he started 4 games, while Harbaugh recovered from a fractured right hand he suffered when he scuffled with NBC sportscaster Jim Kelly. Against the Buffalo Bills, he was winning 26–0 in the first half, but the lead disappeared after the Bills outscored the Colts 30–3, Justin made it close again at 37–35 with 14 seconds remaining, but could not complete the potential game-tying two-point conversion. The Bills recovery from a 26-point deficit at the time was the second-largest comeback in NFL history. Coming in with an 0–10 record against the defending Super Bowl champions Green Bay Packers, he led the team to a 41–38 win, completing 24-of-30 attempts for 340 passing yards. On December 5, he was placed on the injured reserve list.