It's called the Roy Williams rule because he wiped out Terrel Owens with it, which finally sparked the rule change.... but the actual move has been in football since long before 2002
He injured several players over the course of a few years, which caused the rule change, not just T.O.
The move may have been sprinkled in here and there pre-Roy, but it wasn’t until him that it became a deliberate act that needed to be legislated out.