A similar question was posed in Jerry Markbreit's column this week. On whether or not a penalty for holding would be called, Jerry states that "an effort to appear to be in possession of the ball is the determining factor." In other words- if he's not pretending to have the ball (i.e. pretending to be the runner) then tackling him is a penalty for holding.
Jerry's column (mostly focusing on NFL rules) can be seen at chicagosports.com
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