Posted by ESPN.com's Mike Sando

Team NFC West Player Pos. Penalties Penalty Yards STL Richie Incognito OL 4 35 SF Justin Smith DL 3 31 ARI Mike Gandy OL 3 25 STL Alex Barron OL 3 20 ARI Levi Brown OL 3 20 SF Shaun Hill QB 3 20

My appreciation for veteran defensive end Justin Smith has grown tremendously since I've been covering the NFC West and watching every 49ers game.

Smith is a relentless, hard-nosed player. He is very strong. Not many defensive linemen can get under Steve Hutchinson and drive the Pro Bowl guard backward. Smith did it Sunday and still had the wherewithal launch himself into Brett Favre.

The play drew a 15-yard penalty for unnecessary roughness. Referee Jerome Boger called it a "low blow to the quarterback" and it was, but I'm not sure what else Smith could have done. He and Hutchinson seemed to be falling to the ground while Smith continued his push to the quarterback.

"That is a horrible call," Fox analyst and former defensive lineman Tim Ryan said on the broadcast.

Smith has two 15-yard penalties and three penalties overall this season, unusual for him. Smith had one penalty all last season.

The chart shows NFC West penalty leaders through Week 3. The Rams and Cardinals each have two offensive linemen in the top six. Richie Incognito led the NFC West with 13 last season. Alex Barron had 11. The Cardinals' Deuce Lutui had 10 last season. He has only one so far in 2009.

The 49ers' Shaun Hill drew three at Minnesota in Week 3, one for grounding and two for delay of game.