From this MLB.com story:
Howard ruled safe despite missing plate | MLB.com: News
"According to Rule 7.10 (d), the play must be appealed "before the next pitch, or any play or attempted play." Posada's throw to second represented an "attempted play," and therefore eliminated the possibility for the Yankees to appeal the play. "
Actually, I think CC recovered the ball and threw to 2B. But why wouldn't continuous action apply here?