How many ways can you characterize a guy for not being tough? Maybe because the teams he's played on have never earned that distinction.
For whatever reason, Manning's teams in Indy and in Denver have simply not been considered "tough" teams. Perhaps that's because any team with Manning on it will be a high-octane offense (and would be insane to build as ground-and-pound outfit), but even on the defensive side of the ball, Manning's teams have never inspired fear. Why has that always seemed to be the case? Why do certain teams—the Ravens, Seahawks, 49ers, and so on—construct nasty, rugged images, while others don't?