It's been known for a while that Tecmo Super Bowl had some text in it relating to penalties in addition to unused "Sound 32"
You might have missed, like I did back in 2009, that there was an actual set of penalty cut screens still in the game.
Today I stumbled across this and thanks to this handy spreadsheet, inserted them in place of the intro screen event to see them in action.
Here's a video
Also I've uploaded a rom where the intro and start screen are replaced with the penalty cut screens in case you want to see it in action.