One reason: Titans quarterback Marcus Mariota won't play again this year, according to NFL Media's Rand Getlin, due to a minor knee sprain. That puts the Titans' 3-11 record in the hands of backup Zach Mettenberger, who is 0-8 for his career as a starting quarterback. If Mettenberger isn't able to break into the win column, Tennessee will finish 3-13 and the Browns, even if they were to finish 3-13 as well, likely wouldn't overcome the strength-of-schedule tiebreaker, which favors the team with the weaker schedule.
Tennessee opponents have a winning percentage of .492, while Cleveland's opponents are at .520. With just two weeks left in the season, that's an increasingly significant discrepancy, and the last two opponents for each won't do anything to help the Browns in that regard. Tennessee's last two foes are the Texans and Colts, who are 13-15 between them, while Cleveland finishes with playoff contenders Pittsburgh and Kansas City, each 9-5. Although the records of all opponents impact strength-of-schedule ratings each week, the Titans' hold on the No. 1 pick is looking much more secure barring, of course, a win.
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