he doesnt have to take a hit for it to be Jay's fault. An underthrown pass or a pass thrown behind a receiver can force him to make a cut that results in an injury.
That being said, I dont think you can lay the blame on Jay for this one...at least not with any certainty. Even if it was a bad pass, all QBs thow bad passes from time to time. Marino did every now and then. So did Elway. And Montana. Peyton will throw a bad one occasionally now. Sometimes these passes hurt the receivers, sometimes they dont. Now you can argue that since the frequency of poorly thrown balls is MUCH higher with Jay, that the likelyhood of getting getting hurt catching Jay's passes is greater, but I dont think you can argue that THIS particular pass was the cause of Bostons injury.