I've pasted the rule below. It is written in a confusing fashion and it seems clear that many officials are over-aggressive with the call. Look at the Penn State player that was ejected. He was simply playing the ball for an INT and knocked heads by accident with the Michigan receiver. Targeting? Not by any reasonable definition of the rule. Franklin was right to be upset.
The hits on Leidner were late hits IMO and could have been called for targeting based on an overly literal interpretation of the rule. When is a hit considered "forcible"?
IMO there has to be an intent to injure and that's being mostly ignored. It's pretty obvious IMO when someone is spearing someone unnecessarily vs incidental contact such as the Penn State situation, Celestin's hit, or even Josey Jewell's hit.
No player shall target and make forcible contact to the head or neck area of a defenseless opponent (See Note 2 below) with the helmet, forearm, hand, fist, elbow or shoulder. This foul requires that there be at least one indicator of targeting (See Note 1 below). When in question, it is a foul (Rules 2-27-14 and 9-6). (A.R. 9-1-4-I-VI)
Note 1: "Targeting" means that a player takes aim at an opponent for purposes of attacking with forcible contact that goes beyond making a legal tackle or a legal block or playing the ball. Some indicators of targeting include but are not limited to:
--Launch—a player leaving his feet to attack an opponent by an upward and forward thrust of the body to make forcible contact in the head or neck area
--A crouch followed by an upward and forward thrust to attack with forcible contact at the head or neck area, even though one or both feet are still on the ground
--Leading with helmet, shoulder, forearm, fist, hand or elbow to attack with forcible contact at the head or neck area
--Lowering the head before attacking by initiating forcible contact with the crown of the helmet