On occasion, a National Football League team has also been accused of throwing its final regular-season game in an attempt to "choose" its possible opponent in the subsequent playoffs. An alleged example of this was when the San Francisco 49ers, who had clinched a playoff berth, lost their regular-season finale in 1988 to the Los Angeles Rams, thereby knocking the New York Giants (who had defeated the 49ers in the playoffs in both 1985 and 1986, also injuring 49er quarterback Joe Montana in the latter year's game) out of the postseason on tiebreakers; after the game, Giants quarterback Phil Simms angrily accused the 49ers of "laying down like dogs."