Incognito started all nine games in which he played for the Rams in 2009. On December 13, during the first half of a 47-7 loss to the Tennessee Titans, Incognito drew two 15-yard penalties for headbutting Titans players. Head coach Steve Spagnuolo benched him for the second half, and the two got into a heated confrontation on the sidelines. It was the second time Incognito had been benched for losing his composure; he'd been pulled from the season opener against Seattle for two personal fouls. However, the Titans incident was the last straw; the Rams waived him two days after the game