In the 2012 National League Wild Card Game against the St. Louis Cardinals, Simmons hit an eighth-inning fly ball to left field that dropped in between Cardinals shortstop Pete Kozma and left fielder Matt Holliday. Simmons was believed by many to have been entitled to a single, but left field umpire Sam Holbrook cited the infield fly rule and called Simmons out. Angered Braves fans littered the field with trash, causing a 19-minute delay and a threatened forfeit. The Braves lost the game 6–3 and were eliminated.